In Palma v. U.S. Industrial Fasteners, Inc. (1984) 36 Cal.3d 17, a former employee of the defendant stole the defendant's flatbed truck from an unfenced lot in front of the defendant's property, which was located in a high-crime industrial area. (Id. at pp. 184, 186.) The door and window of the truck were open and the keys were in the glove compartment. (Id. at p. 184.) The thief drove the truck to a location where injury to the plaintiff occurred. (Id. at p. 176.) The California Supreme Court in Palma found "a foreseeable risk of harm was posed by the truck left with its keys in the ignition or cab warranting imposition of a duty on the owner or operator to refrain from exposing third persons to the risk." (Palma, supra, 36 Cal.3d at p. 185.) Palma reiterated: "The 'special circumstance' to which we look in determining whether the owner operator of a vehicle owes a duty to third parties in the manner in which the vehicle is secured when not in use is nothing more than a test of foreseeability of harm." (Id. at p. 186)