Brandy S Lewis v. Jennifer Rejniak

CourtMichigan Court of Appeals
DecidedFebruary 22, 2024
Docket363974
StatusUnpublished

This text of Brandy S Lewis v. Jennifer Rejniak (Brandy S Lewis v. Jennifer Rejniak) 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
Brandy S Lewis v. Jennifer Rejniak, (Mich. Ct. App. 2024).

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

BRANDY S. LEWIS, UNPUBLISHED February 22, 2024 Plaintiff-Appellant,

v No. 363974 Macomb Circuit Court JENNIFER REJNIAK, LC No. 2021-003060-NO

Defendant-Appellee.

Before: BOONSTRA, P.J., and LETICA and FEENEY, JJ.

PER CURIAM.

In this premises’ liability slip-and-fall action, plaintiff appeals as of right the order granting summary disposition to defendant, under MCR 2.116(C)(10) (no genuine issue of material fact). The trial court determined that the hazard causing plaintiff’s injury was open and obvious and not effectively unavoidable. On appeal, plaintiff argues the trial court erred because plaintiff was an invitee on defendant’s property1 and the hazard was effectively unavoidable. In light of developments in the law since the filing of this appeal, we vacate and remand for further proceedings.

I. BACKGROUND FACTS AND PROCEDURAL HISTORY

On Sunday, February 7, 2021, defendant placed an order for groceries through Shipt, a delivery service.2 According to defendant, she frequently used Shipt to place grocery orders for same-day delivery, designated a time block for delivery, and instructed that her orders be left on the porch.3

1 We note that the trial court did not hold otherwise. 2 Except as otherwise noted, our description of the underlying facts is taken from plaintiff’s complaint and deposition testimony. 3 Plaintiff testified the items were to be delivered to the front door, which was on the porch.

-1- Plaintiff, who worked for Shipt, picked up defendant’s order from the Shipt app that afternoon. Plaintiff notified defendant that she would be shopping for her, informing defendant that she could send plaintiff a text message if she had a question. When items defendant had selected were unavailable, plaintiff communicated with defendant via text regarding substitutions or cancellations. After plaintiff finished shopping, she texted defendant that she was on her way and would see her “soon!” Defendant replied, “Ok.”

Plaintiff drove to defendant’s home and pulled into driveway. As plaintiff, who was wearing boots, got out of her car, she noticed “fresh” snow that had fallen the night before on the driveway, the short walkway to the porch steps, the two porch steps leading to the porch, and the porch itself. There was no hand rail. Plaintiff carried a large bag of pet food toward the porch, avoiding the short walkway by traversing defendant’s snow-covered lawn. Plaintiff then walked up the two porch steps, deposited the bag, and carefully began her descent before slipping on the first step, and falling. Plaintiff hit her tailbone and her head. From what plaintiff observed, she opined that there had been no attempt to shovel or salt the snow on the porch, sidewalk, or driveway.

After falling, plaintiff returned to her car and called Shipt to report the incident. Plaintiff then delivered the remaining items to defendant’s porch, including two cases of water, without further incident. Plaintiff photographed the completed delivery and texted defendant “[y]our groceries are delivered.” Plaintiff sent a second text, reading: “Please for future reference shovel you [sic] snow, I just fell down your stairs and hit my head[.]”

Plaintiff left to make her next delivery. Because plaintiff was running late, she contacted her next customer, who had been watching for her, explaining that she had fallen. That customer met plaintiff outside to collect their order.

Plaintiff subsequently discovered that she was seriously injured from her fall at defendant’s home.

According to defendant, she left her ranch home for work at about 6:30 a.m. on the morning of plaintiff’s fall, while her two teenage children remained inside. Defendant had shoveled her front porch, steps, walkway, and driveway the night before. Defendant also typically used ice- melting salt on those areas. Defendant’s mail slot was accessible from her porch so she cleaned the snow and ice as a courtesy for her mail carrier and everyone else. Defendant never received a warning from her mail carrier that delivery would not continue due to the condition of her porch and stairs. Defendant’s son also shoveled as one of his chores.

Defendant had no evidence to dispute weather records showing that “it had snowed again throughout the night [on the 6th] and in the early morning hours up until 3:30” or 4 a.m. on the 7th. When defendant left for work that morning, she may have thrown down additional salt. And, if defendant had noticed “extreme” snow or ice on her porch or stairs, she would have shoveled again. Defendant did not recall whether she shoveled that morning; however, she recalled safely traversing her porch, stairs, walkway, and driveway to reach her car. Defendant pointed to bare areas around her front door mat in the photograph plaintiff had texted her as evidence that defendant had shoveled earlier.

-2- It is undisputed that defendant did not warn plaintiff about the condition of her premises before she arrived. It is further undisputed that plaintiff did not communicate with defendant that she was uncomfortable with the delivery due to the snow or request to deliver defendant’s order at an alternate location.

On August 19, 2021, plaintiff filed a complaint against defendant, alleging negligence in the maintenance of defendant’s property. More specifically, plaintiff alleged that she was compelled to encounter the hazard to complete the delivery at defendant’s front door, as required by the terms of her employment with Shipt, and that she exercised all due care in encountering the hazard. Among her allegations of negligence, plaintiff contended that defendant “[c]reat[ed] a dangerous condition or contibut[ed] to the creation of a dangerous condition on the premises.”

After discovery ended, defendant moved for summary disposition, asserting plaintiff was a licensee, and not an invitee because defendant was not a business enterprise and did not hold her property open to the public. Defendant further contended that the ice and snow on the porch and step constituted an open and obvious hazard, which plaintiff was not compelled to encounter, and therefore, no special aspects existed negating the application of the open and obvious doctrine.

Plaintiff responded, asserting her status was one of an invitee, and that the open and obvious doctrine could not negate defendant’s liability because plaintiff was compelled to complete her assigned work task of delivering defendant’s order to the porch, rendering the hazard effectively unavoidable. Plaintiff further argued defendant was actively negligent.

At the hearing on defendant’s motion for summary disposition, the circuit court initially expressed skepticism that the hazard was unavoidable in light of plaintiff’s ability to communicate with defendant. The court stated that there was no evidence that Shipt had a policy requiring plaintiff to endanger herself by walking on an ice-covered porch.

Addressing defense counsel, the trial court expressed that this case was “borderline as to what the [plaintiff’s] options were.” Defense counsel responded that while he may not have mentioned it in his briefing, plaintiff’s communication with her subsequent customer demonstrated that she had that option available. The circuit court informed the parties that it had denied the defendant’s motion for summary disposition in Estate of Living v Sage’s Investment Group, LLC, 507 Mich 328; 968 NW2d 397 (2021), because the hazardous condition, a snow- and ice-covered parking lot, was unavoidable when the plaintiff, the defendant’s employee, had to cross it to get to her job.

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Cite This Page — Counsel Stack

Bluebook (online)
Brandy S Lewis v. Jennifer Rejniak, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brandy-s-lewis-v-jennifer-rejniak-michctapp-2024.