Rankin's Garage v. J.J.: Is a Business Liable When Teens Steal a Car?

Rankin's Garage & Sales v. J.J., 2018 SCC 19, is a key Supreme Court of Canada decision on when a duty of care exists in negligence.

What happened

Two teenagers went onto the lot of a commercial garage in Saskatchewan at night, found an unlocked car with the keys inside, and took it. The car crashed, and the passenger, a teen, suffered a serious brain injury. He sued the garage for negligence.

What the court decided

A majority of the Supreme Court held that the garage didn't owe a duty of care. The question was whether a reasonable person in the garage's position would have foreseen the risk of physical injury, not just theft. On the evidence, the court found that risk wasn't reasonably foreseeable.

Why it matters

• Foreseeability is the starting point for a duty of care.
• The type of harm matters: foreseeing property theft isn't the same as foreseeing injury.

What it means for you

• Businesses: securing vehicles and premises is still good practice, and can be required by other laws or insurance.
• Injured people: a negligence claim must show the defendant owed you a duty in the first place.

Sources

• Rankin's Garage & Sales v. J.J., 2018 SCC 19 (CanLII)
• Donoghue v. Stevenson and duty of care (NEO guide)

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General Ontario legal information, not legal advice for your matter, and reading it does not create a retainer. Sources checked 15 October 2026: check the current law, forms and dates before you act.

Photos from Pexels: A parking lot seen from above · A car dashboard on an open road.

This article is general information for people in Ontario, not legal advice. Rules, forms and deadlines change, and every situation is different. Check the current rule or speak to a licensed legal professional before you act.