“What grocery store have you been to that hasn’t been negligent with their shopping carts at least once per week yet along several times per day.”
None.
Leaving a few carts loose in the lot is not negligence if you have a program of maintaining the carts. Every store I go to has cart return areas and active cart retrieval programs.
Cart return areas don’t mean jack. Unless they are in every other parking spot. You just need one that is “far” away and you win.