In Jefferson v. Qwik Korner Market, Inc. (1994) 28 Cal.App.4th 990, a minor was standing on the sidewalk in front of a convenience store. An 84-year-old driver was pulling into a parking space in front of him. Suddenly the driver's foot ped, and the car jumped both the parking blocks and the curb of the sidewalk, hitting the minor. In rejecting the idea that the convenience store had a duty to protect against that particular risk, we noted that liability of landowners to pedestrians hit by negligent third party drivers has only been predicated on one of three scenarios: (1) "no protection whatever from encroaching vehicles" (see Jefferson, supra, 28 Cal.App.4th at p. 994); (2) "knowledge of prior similar incidents" (ibid.); (3) a configuration in which the plaintiff will be in a specific fixed location which is especially vulnerable to any cars whose drivers might lose control ( id. at p. 995). In Jefferson v. Qwik Korner Market, Inc. (1994) a convenience store customer was injured while standing in front of the store when a car jumped over both a parking block and the curb and hit him. He brought a personal injury action against the convenience store. The trial court granted summary judgment for the defendant. (Id. at p. 992.) After reviewing a number of cases from other states, the Fourth District Court of Appeal affirmed, holding that the trial court properly granted summary judgment for the defendant. The defendant had provided both a curb and a parking block. The parking lot was typical of most businesses and met all city standards and regulations. There were no similar incidents and nothing required customers to remain in a fixed location adjacent to the parking area. Under the circumstances, the accident was not "sufficiently likely," and therefore not reasonably foreseeable, and the defendant had no duty to erect additional barriers. (Id. at pp. 995-996.) However, the Fourth District Court of Appeal noted that in a minority of cases courts have held that liability is a question of fact for the jury. These cases fall into one of three categories. In the first category are cases where the business provides no protection from encroaching vehicles. In the second, the defendants had knowledge of prior similar incidents. Therefore, the accidents were deemed foreseeable, even when there was some type of barrier. Then there is a third category of cases where the building design required customers to await service by standing adjacent to a parking lot or driveway. Thus, if a car jumped the curb, there was a high likelihood that a pedestrian would be at the location. (Id. at pp. 994-996.)