Law School Case Brief
Riddle v. McLouth Steel Prods. Corp. - 440 Mich. 85, 485 N.W.2d 676 (1992)
In the determination of the scope of a premises owner's duty to invitees where known or obvious conditions are present, an invitee who enters land is entitled to nothing more than knowledge of the conditions and dangers he will encounter if he comes. If he knows the actual conditions, and the activities carried on, and the dangers involved in either, he is free to make an intelligent choice as to whether the advantage to be gained is sufficient to justify him in incurring the risk by entering or remaining on the land. The possessor of the land may reasonably assume that he will protect himself by the exercise of ordinary care, or that he will voluntarily assume the risk of harm if he does not succeed in doing so. Reasonable care on the part of the possessor therefore does not ordinarily require precautions, or even warning, against dangers which are known to the visitor, or so obvious to him that he may be expected to discover them.
Plaintiff Vance Riddle was injured as he walked across defendant premises owner McLouth Steel's plant where coils of wire were stored and where oil dripped regularly in a process called "pickling." Prior to walking across the plant floor, Riddle had observed McLouth Steel's employees cleaning the area. While crossing the coil field, Riddle lost his balance, fell backwards, and hit his head on metal rails set in the floor to hold the coils of steel. Riddle brought a personal injury action against McLouth Steel. The jury returned a verdict for Riddle. On appeal, McLouth Steel alleged that the trial court erred in instructing the jury on McLouth Steel's duty to Riddle. The appellate court affirmed.
Did defendant premises owner McLouth Steel have a duty to warn plaintiff invitee Riddle of an obvious danger in the plant?
On further appeal, the Supreme Court of Michigan reversed the judgment and the award of damages to plaintiffs. The Court held that the trial court erred in instructing the jury and that the appellate court erred in concluding that Michigan had abolished the rule that a premises owner had no duty to warn an invitee of a known or an obvious danger. Plaintiff Riddle delivered the steel coils to the plant and was aware that the coils dripped oil. Riddle knowingly walked across the plant area where the steel coils were stored, and the oil on the floor was obvious.
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