While Kathy Brown was ordering a meal from a Kentucky Fried Chicken restaurant in Redondo Beach, California, an armed robber entered the store, pressed his gun to her back, and lifted her wallet. He then demanded that the KFC employee give him the cash in the register as well, shoving his gun harder into Ms. Brown's back and threatening to shoot. The frightened cashier told the robber she would have to get the key from the back of the store. Brown screamed for the cashier to turn over the money, the cashier complied, and seconds later the robber fled with the loot. He was never apprehended.

A year later, Brown sued KFC for severe emotional distress. Ruling in her favor, a California appellate court accepted her hypothesis that a company has a duty to comply with a robber's demands and is liable to tort action from injured or frightened patrons if it fails to do so quickly enough.

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