appeal, the Second Circuit held that BMW/NA had no duty to prevent the customer’s loss caused by the president’s criminal activity and reversed the judgment for the customer. Id. at 1101. The Second Circuit explained: [T]he district court improperly determined that [the customer’s] injury was reasonably foreseeable, and thus erred in finding BMW/NA liable for negligent failure to police the methods of operation of its independent franchisee and to terminate the fr 4 Ga.App. 38, 668 S.E.2d 737, 747-49 (2008) (finding that a franchisor owed no duty to a customer defrauded by one of its franchisees under either the Georgia Franchise Practices Act or the franchise agreement); see also Freedman v. Tenn Dev. Corp., No. 91-475 LON, 1993 U.S. Dist. LEXIS 11021, at *39-47 (D.Del. Aug. 3, 1993) (<HOLDING>). Like the franchisor in Cullen, Jackson Hewitt
holding that a franchisor had no duty to supervise a potential franchisees activities in soliciting financing from private investors holding that no private right of action exists holding where there is no duty to defend there is no duty to indemnify holding that duty to defend ends when it is apparent there is no potential for coverage holding that under section 25303 the board of supervisors has a statutory duty to supervise the conduct of all county officers