In Herrera v. Quality Pontiac, 2003 NMSC 18, 134 N.M. 43, 73 P.3d 181, the New Mexico Supreme Court addressed the issue of whether a car dealership should have foreseen that its actions in requiring customers to leave their keys in unlocked and unattended vehicles necessarily increased the likelihood that a criminal act would occur. 2003 NMSC 182, 134 N.M. 43, 73 P.3d 181. In concluding that the foreseeability element of duty was met, the Court in Herrera relied primarily on statistics demonstrating the high rate of car thefts in Albuquerque and that stolen vehicles "are much more likely to be involved in automobile accidents." Id. The Court also relied on the "defendant's actions in directing the owner to leave the keys in the vehicle and leaving the vehicle unlocked and unattended" to conclude that the defendant created a risk of theft. Id.