Maybe a jogger going for his weekly workout.
That's also the biggest issue with the phone key atm. It's easy to forget you left it in the wireless charging cradle, the car should give you a gentle chime or reminder if you've opened the door with the phone still charging inside...
As I mentioned in another post, it would also be completely possible today to emulate the keycard and add it as an NFC card on your Apple Watch wallet. But that requires just a couple hours of dev from Tesla... which they apparently aren't wiling to do just yet...