20250124_C365585_62_365585.Opn.Pdf

CourtMichigan Court of Appeals
DecidedJanuary 24, 2025
Docket20250124
StatusUnpublished

This text of 20250124_C365585_62_365585.Opn.Pdf (20250124_C365585_62_365585.Opn.Pdf) is published on Counsel Stack Legal Research, covering Michigan Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
20250124_C365585_62_365585.Opn.Pdf, (Mich. Ct. App. 2025).

Opinion

If this opinion indicates that it is “FOR PUBLICATION,” it is subject to revision until final publication in the Michigan Appeals Reports.

STATE OF MICHIGAN

COURT OF APPEALS

JAMES HOLLIDAY, UNPUBLISHED January 24, 2025 Plaintiff-Appellant, 1:37 PM

v No. 365585 Wayne Circuit Court KS PROPERTY MANAGEMENT CORP, LC No. 22-001563-NO

Defendant, and

KS LANDSCAPING LLC and TRENTON LEISURE MEADOWS ASSOCIATION,

Defendants-Appellees.

Before: FEENEY, P.J., and SWARTZLE and CAMERON, JJ.

PER CURIAM.

In this slip-and-fall case, plaintiff appeals as of right from the order granting summary disposition to defendant, Trenton Leisure Meadows Association (“Trenton”), under MCR 2.116(C)(8) (failure to state a claim) and (10) (no genuine issue of material fact), and to defendant, KS Landscaping, LLC (“KSL”), under MCR 2.116(C)(10). On appeal, plaintiff argues the trial court erred by granting summary disposition to Trenton because the court incorrectly found that Trenton owed no duty to plaintiff under a premises-liability theory based on this Court’s flawed decision in Francescutti v Fox Chase Condo Ass’n, 312 Mich App 640, 642-643; 886 NW2d 891 (2015), overturned by Janini v London Townhouses Condo Ass’n (Janini III), ___ Mich ___, ___; ___ NW3d ____ (2024) (Docket No. 164158); slip op at 15. Moreover, plaintiff’s claims sounded in both premises liability and negligence, and Trenton breached its statutory duties owed to plaintiff under the Housing Law of Michigan (HLM), MCL 125.401 et seq. Plaintiff also argues the trial court incorrectly granted summary disposition to KSL because KSL’s contractual obligations owed to Trenton did not relieve it of liability for plaintiff’s injuries under a negligence theory and there was a genuine issue of material fact whether KSL breached its common-law duties owed to plaintiff.

-1- Because Francescutti was binding law at the time the trial court granted summary disposition to Trenton, the trial court did not err by relying on its holding to find that Trenton owed no duty to plaintiff under a premises-liability theory. But because our Supreme Court in Janini III, ___ Mich at ___; slip op at 15, overturned Francescutti, we reverse the trial court’s order granting summary disposition to Trenton regarding plaintiff’s premises-liability claims. With respect to plaintiff’s negligence claims against Trenton, the trial court did not err by granting summary disposition to Trenton because plaintiff’s claims sounded solely in premises-liability law and the HLM is inapplicable. Finally, because plaintiff failed to establish that KSL breached a duty separate and distinct from KSL’s contractual obligations to Trenton, the trial court did not err by granting summary disposition to KSL. We affirm in part, reverse in part, and remand for further proceedings.

I. BACKGROUND

Plaintiff owned and lived in a condominium within a condominium complex owned and maintained by Trenton. Trenton hired KSL to, among other duties, remove snow and lay down ice melt and rock salt on the roadways, driveways, and walkways that the condominium residents use. On February 13, 2019, at about 7:00 a.m., plaintiff, while walking to his car, slipped and fell on a patch of ice in the condominium complex’s parking lot. As a result of his fall, plaintiff sustained injuries, including a broken leg that required surgical intervention.

In February 2022, plaintiff filed his complaint against defendants,1 alleging that because he was an invitee of the condominium complex and defendants had joint possession and control of the premises where his fall occurred, defendants owed him a duty to properly inspect and maintain the premises. Plaintiff claimed defendants failed to uphold their duty because they did not inspect the premises or remove snow and ice from the common areas of the condominiums, thereby causing plaintiff to sustain serious injuries. Additionally, plaintiff asserted that by failing to remove the snow and ice, defendants violated their statutory duties under the HLM, relevant here, MCL 125.536 (owner of a dwelling permits unsafe, unsanitary or unhealthful conditions to exist unabated in any portion of the dwelling). Plaintiff also argued that defendants were liable for negligence because they negligently performed their duties under the contract and created a new hazard that altered the premises and posed an unreasonable risk of harm. KSL and Trenton answered, denying plaintiff’s allegations as untrue.

After months of discovery, KSL moved for summary disposition under MCR 2.116(C)(10). In accordance with the contract between KSL and Trenton, KSL asserted that, the day before plaintiff’s fall, it “spread 8 bags of ice melt throughout the facility and spread half a ton of rock salt,” and did not return to the property until after plaintiff had already fallen. Thus, KSL “performed its duties consistent with its contractual obligations.” KSL claimed that in order for plaintiff to bring a negligence action based on a breach of contract claim, plaintiff had to allege that KSL breached a separate and distinct duty from its contractual obligation to remove snow from the condominium’s common areas. According to KSL, a separate and distinct duty could include a duty not to create a new hazard, such as piling snow near a walkway. But because there was no evidence that KSL created a new hazard, KSL claimed there was no genuine issue of

1 KS Property Management Corp. was later dismissed by stipulation.

-2- material fact that plaintiff failed to establish a claim of negligence separate from KSL’s contractual obligations. As such, KSL requested the trial court dismiss plaintiff’s claims.

In response to KSL’s motion, plaintiff claimed that “a contracting party’s assumption of a contractual obligation does not extinguish or limit separate, pre-existing common law or statutory tort duties owed to a noncontracting third party in the performance of a contract.” As such, plaintiff claimed that KSL’s snow removal contract did not “absolve it of pre-existing duties to act in a manner so as not to cause harm to others.” In his deposition, plaintiff testified that KSL had not performed snow or ice removal for three to four days before his fall despite significant winter weather, and that KSL “generally did a poor job of snow and ice removal.” Because plaintiff’s testimony created a question of fact regarding whether KSL breached its common-law duty to act in a manner so as to not cause harm, plaintiff argued KSL’s motion should be denied.

Trenton also moved for summary disposition under MCR 2.116(C)(8) and (10), arguing that plaintiff’s claims sounded in premises liability because his injuries arose from a dangerous condition on the land. To succeed in a premises-liability action, Trenton claimed plaintiff must demonstrate that Trenton owed him a duty. In support of its motion, Trenton relied, in part, on this Court’s decision in Francescutti, 312 Mich App at 642-643. In Francescutti, this Court found that condominium owners were “co-owners as tenants in common of the common areas of a condominium development.” Id. at 643. As such, this Court held that because a unit owner is not entering upon “the land of another” when in the common areas, there is no duty owed to him under premises-liability law. Id. Accordingly, Trenton claimed that because plaintiff owned his condominium, Trenton did not owe him any duty, and plaintiff could not assert a premises-liability claim. Additionally, Trenton asserted MCL 125.536 was inapplicable because Trenton was not the owner of the site of the incident and plaintiff’s accident occurred in a parking lot, not in a portion of the dwelling.

In response, plaintiff asserted that there was no basis to Trenton’s assertion that his claims sounded only in premises liability.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Hill v. Sears, Roebuck and Co
492 Mich. 651 (Michigan Supreme Court, 2012)
Hoffner v. Lanctoe
821 N.W.2d 88 (Michigan Supreme Court, 2012)
Loweke v. Ann Arbor Ceiling & Partition Co, LLC
809 N.W.2d 553 (Michigan Supreme Court, 2011)
Fultz v. Union-Commerce Associates
683 N.W.2d 587 (Michigan Supreme Court, 2004)
Quinto v. Cross and Peters Co.
547 N.W.2d 314 (Michigan Supreme Court, 1996)
Stitt v. Holland Abundant Life Fellowship
614 N.W.2d 88 (Michigan Supreme Court, 2000)
Francescutti v. Fox Chase Condominium Association
886 N.W.2d 891 (Michigan Court of Appeals, 2015)
Bruce Millar v. Construction Code Authority
912 N.W.2d 521 (Michigan Supreme Court, 2018)
Jawad a Shah Md Pc v. State Farm Mutual Automobile Insurance Co
920 N.W.2d 148 (Michigan Court of Appeals, 2018)
Estate of Ezekiel D Goodwin v. Northwest Michigan Fair Association
923 N.W.2d 894 (Michigan Court of Appeals, 2018)
John Pugno v. Blue Harvest Farms LLC
930 N.W.2d 393 (Michigan Court of Appeals, 2018)
Boylan v. Fifty Eight Ltd. Liability Co.
808 N.W.2d 277 (Michigan Court of Appeals, 2010)
Buhalis v. Trinity Continuing Care Services
296 Mich. App. 685 (Michigan Court of Appeals, 2012)

Cite This Page — Counsel Stack

Bluebook (online)
20250124_C365585_62_365585.Opn.Pdf, Counsel Stack Legal Research, https://law.counselstack.com/opinion/20250124_c365585_62_365585opnpdf-michctapp-2025.