More than sixty-eight million automobiles were registered in the United States in 1963 alone. This horde of automobiles, along with the mass exodus to the suburbs, has caused shopping centers to become integral parts of community living, and has made facilities for parking around them of principal importance. The resultant revolution in merchandising has extended the property owner's duty of care to include such parking areas.
Beverly E. Sylvester, Shopping Center Parking Lot Liability, 14 Clev.-Marshall L. Rev. 570 (1965)