In Richards v. Stanley (1954) 43 Cal.2d 60, the defendant left her car parked on a street in San Francisco, unlocked and unattended, with the key in the ignition. The car was stolen and, while being driven by the thief, collided with a motorcycle driven by the plaintiff. He sued the owner for negligence, alleging her carelessness had induced the thief to take the car in the first place. (Richards, supra, 43 Cal.2d at pp. 61-62.) The Supreme Court affirmed a judgment of nonsuit, reiterating: "It has generally been held that the owner of an automobile is under no duty to persons who may be injured by its use to keep it out of the hands of a third person in the absence of facts putting the owner on notice that the third person is incompetent to handle it." (Id. at p. 63.) In applying the general rule of nonliability, Richards noted the defendant did not leave the automobile in front of a school where irresponsible children might reasonably be expected to tamper with it "nor did she leave it in charge of an intoxicated passenger ... . By leaving the key in her car she at most increased the risk that it might be stolen." (Richards, supra, 43 Cal.2d at p. 66.) Richards concluded the duty to exercise reasonable care in the management of an automobile "did not encompass a duty to protect plaintiff from the negligent driving of a thief." (Ibid.)