California Supreme Court Rules in Favor of Target: Says There is No Common Law Duty Requiring AEDs in Target Stores

In a long-awaited and important AED-related decision, the California Supreme Court has ruled unanimously that there is no common law duty (aka legally imposed obligation) requiring Target Corporation to obtain and make available AEDs in its stores for use in medical emergencies. This result effectively ends the case but the decision will reverberate in California and courts in other states for many years to come.

By way of background, this case began in 2008 when Mary Ann Verdugo, a 49-year-old developmentally disabled shopper with serious health issues, died after experiencing sudden cardiac arrest at a California Target store. The store lacked an AED or an employee trained to use one, though at the time Target sold AEDs on its website.