A church owed a duty to protect its visitors crossing a busy street from a designated overflow parking lot, the Pennsylvania Superior Court has ruled, clarifying the boundaries of a ruling from last year in which it held that a nightclub owed no such duty under similar circumstances.

In Charney v. Reitz, a three-judge panel of the court unanimously ruled in a nonprecedential decision that defendant Friends of Peace Church (FOPC) owed a duty to D’Arcy Wagonhurst, an 84-year-old woman who was struck and killed by a car while crossing a busy street to attend a Christmas program at the church. Wagonhurst had parked in a private commercial lot that the church had instructed visitors to use.