I'd guess this depends on state laws and circumstances.
And if you leave your keys in the car …. Well …. No sympathy here.
Hard to believe that in this day and age anyone leaves the keys in the car, even if garaged. I guess growing up in Brooklyn, NY made me leery of EVER leaving keys around. If I go for gas, and need to go into the store at the gas station, the engine is off and the keys in my pocket. About the only time I might exit my car and leave the keys there with the engine running is when stopped in my driveway and I get out to get the mail out of the mailbox. When I go away for an overnight or longer, the keys to my other vehicles (cars and motorcycles) go into my safe so that if my home were broken into I have not made it easy for the thief to have any of my vehicles for a getaway.