Anne Jenkins v. C&W Johnson MGT Co., JMCII/JMC Partners D/B/A McDonald's

CourtCourt of Appeals of Texas
DecidedAugust 21, 2025
Docket02-25-00057-CV
StatusPublished

This text of Anne Jenkins v. C&W Johnson MGT Co., JMCII/JMC Partners D/B/A McDonald's (Anne Jenkins v. C&W Johnson MGT Co., JMCII/JMC Partners D/B/A McDonald's) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Anne Jenkins v. C&W Johnson MGT Co., JMCII/JMC Partners D/B/A McDonald's, (Tex. Ct. App. 2025).

Opinion

In the Court of Appeals Second Appellate District of Texas at Fort Worth ___________________________ No. 02-25-00057-CV ___________________________

ANNE JENKINS, Appellant

V.

C&W JOHNSON MGT CO., JMCII/JMC PARTNERS D/B/A MCDONALD’S, Appellee

On Appeal from the 362nd District Court Denton County, Texas Trial Court No. 23-8527-362

Before Sudderth, C.J.; Bassel and Womack, JJ. Memorandum Opinion by Justice Bassel MEMORANDUM OPINION

I. Introduction

While attempting to walk to Appellee C&W Johnson Mgt Co., JMCII/JMC

Partners d/b/a McDonald’s (McDonald’s) from an elevated parking area adjacent to

the McDonald’s parking lot on a clear, sunny afternoon, Appellant Anne Jenkins fell

and suffered injuries when she stepped on a sloped transition between the two curbs

that joined the parking lots. She sued McDonald’s for premises liability, alleging that

the downward slope was unmarked, unguarded, and hidden from her view by the

general landscape and that the “unmarked, hidden, sudden change in elevation in [the

path that she took] constitutes an unreasonably dangerous condition upon the

premises about which [McDonald’s] knew or should have known.” McDonald’s filed

a no-evidence motion for summary judgment arguing, among other things, that

McDonald’s had no duty to warn Jenkins of the complained-of condition because it

was open and obvious.1 The trial court granted the motion without specifying the

ground(s) upon which it was granted. In a single issue, Jenkins argues that the trial

court’s ruling was error. Because the slope between the curbs was open and obvious,

we affirm the trial court’s judgment.

1 McDonald’s made this argument in its motion under the heading “There is No Evidence That Defendant had Constructive Knowledge of the Alleged Condition and the Alleged Condition was Open and Obvious.”

2 II. Discussion

The crux of this appeal is whether Jenkins produced more than a scintilla of

probative evidence showing that the slope between the curbs was not an open and

obvious danger. Because we conclude that she did not do so and therefore produced

no evidence that McDonald’s had a duty to warn or make safe, we hold that the no-

evidence summary judgment was proper.

A. Standard of Review and Governing Law

When reviewing a no-evidence summary judgment, we examine the entire

record in the light most favorable to the nonmovant, indulging every reasonable

inference and resolving any doubts against the motion. Sudan v. Sudan, 199 S.W.3d

291, 292 (Tex. 2006). We review a no-evidence summary judgment for evidence that

would enable reasonable and fair-minded jurors to differ in their conclusions.

Hamilton v. Wilson, 249 S.W.3d 425, 426 (Tex. 2008) (citing City of Keller v. Wilson, 168

S.W.3d 802, 822 (Tex. 2005)). We credit evidence favorable to the nonmovant if

reasonable jurors could, and we disregard evidence contrary to the nonmovant unless

reasonable jurors could not. Timpte Indus., Inc. v. Gish, 286 S.W.3d 306, 310 (Tex.

2009) (citing Mack Trucks, Inc. v. Tamez, 206 S.W.3d 572, 582 (Tex. 2006)).

When a defendant files a no-evidence motion for summary judgment

challenging an essential element of the plaintiff’s claim—as McDonald’s did—the

burden shifts to the plaintiff to produce evidence raising a genuine issue of material

fact on the challenged element. Tex. R. Civ. P. 166a(i); JLB Builders, L.L.C. v.

3 Hernandez, 622 S.W.3d 860, 864 (Tex. 2021); Mack Trucks, 206 S.W.3d at 581–82. If

the plaintiff responds with more than a scintilla of probative evidence to support the

challenged element, then summary judgment is improper. JLB Builders, 622 S.W.3d at

864.

Generally, a premises owner (here, McDonald’s) owes an invitee (Jenkins)2 a

duty to make safe or warn against concealed, unreasonably dangerous conditions of

which the premises owner is or should be aware and the invitee is not. See Taylor v.

Goodwill Indus. of Fort Worth, No. 02-23-00328-CV, 2024 WL 1100872, at *1 (Tex.

App.—Fort Worth Mar. 14, 2024, no pet.) (mem. op.). But if a hazard is open and

obvious, then the invitee is charged with awareness of the danger, and the premises

owner “has no obligation to warn . . . or make the premises safe, as a matter of law.”3

Los Compadres Pescadores, L.L.C. v. Valdez, 622 S.W.3d 771, 788 (Tex. 2021). As the

Dallas Court of Appeals has noted,

The Texas Supreme Court has “declined to impose a duty for premises conditions that are open and obvious, regardless of whether such conditions are artificial or naturally occurring.” 4Front Eng[’]g Sol[s.], Inc. v. Rosales, 505 S.W.3d 905, 912 (Tex. 2016). In 4Front, the plaintiff was injured on defendant’s premises when an electrician hired by defendant to repair a sign drove the scissor lift in which plaintiff was riding off the sidewalk, causing the lift to topple and injure plaintiff. See id. at 906–07.

2 The parties agree that Jenkins was an invitee, i.e., a person “who enters the property of another ‘with the owner’s knowledge and for the mutual benefit of both.’” Austin v. Kroger Tex., L.P., 465 S.W.3d 193, 202 (Tex. 2015) (quoting Motel 6 G.P., Inc. v. Lopez, 929 S.W.2d 1, 3 (Tex. 1996)).

There are a few exceptions to this rule, see Austin, 465 S.W.3d at 204–08, but 3

Jenkins does not claim that an exception applies.

4 The court declined to impose a duty for premises conditions that were open and obvious “even if the sidewalk’s edge was dangerous and did proximately cause the accident.” Id. at 912.

Biggs v. Bradford Mgmt. Co., No. 05-17-00869-CV, 2018 WL 3629106, at *3 (Tex.

App.—Dallas July 31, 2018, pet. denied) (mem. op.).

A danger is open and obvious if a reasonably prudent invitee would have

known and appreciated the nature and extent of the danger under similar

circumstances. Los Compadres Pescadores, 622 S.W.3d at 788. This is a case-specific,

objective test that is based on the totality of the circumstances, and it is a question of

law. Id. at 788–89; see Culotta v. DoubleTree Hotels LLC, No. 01-18-00267-CV, 2019 WL

2588103, at *3 (Tex. App.—Houston [1st Dist.] June 25, 2019, pet. denied) (mem.

op.) (noting that both duty and the open-and-obvious doctrine are questions of law).

B. Open and Obvious Slant Between the Curbs

Jenkins claims that the following photographic evidence that she presented

raised a genuine issue of material fact that the sloped walking surface was not open

and obvious to invitees:

5 6 She further contends that the condition was not open and obvious because she “had

no warning from [McDonald’s] that the walking path was sloped or that there would

be a change in elevation. There was also [no] signage, markings, or warnings that

would have put [her] on notice of the condition.” And she relies on the following

from her expert’s report: 4

As Ms.

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Related

MacK Trucks, Inc. v. Tamez
206 S.W.3d 572 (Texas Supreme Court, 2006)
Hamilton v. Wilson
249 S.W.3d 425 (Texas Supreme Court, 2008)
Timpte Industries, Inc. v. Gish
286 S.W.3d 306 (Texas Supreme Court, 2009)
Burns v. Baylor Health Care System
125 S.W.3d 589 (Court of Appeals of Texas, 2003)
Motel 6 G.P., Inc. v. Lopez
929 S.W.2d 1 (Texas Supreme Court, 1996)
City of Keller v. Wilson
168 S.W.3d 802 (Texas Supreme Court, 2005)
Randy Austin v. Kroger Texas, L.P.
465 S.W.3d 193 (Texas Supreme Court, 2015)
Martin Rodriguez v. Cemex, Inc.
579 S.W.3d 152 (Court of Appeals of Texas, 2019)
Sudan v. Sudan
199 S.W.3d 291 (Texas Supreme Court, 2006)

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Bluebook (online)
Anne Jenkins v. C&W Johnson MGT Co., JMCII/JMC Partners D/B/A McDonald's, Counsel Stack Legal Research, https://law.counselstack.com/opinion/anne-jenkins-v-cw-johnson-mgt-co-jmciijmc-partners-dba-mcdonalds-texapp-2025.