Yarrick v. Village of Kent City

473 N.W.2d 774, 189 Mich. App. 627
CourtMichigan Court of Appeals
DecidedJune 3, 1991
DocketDocket 131035
StatusPublished
Cited by5 cases

This text of 473 N.W.2d 774 (Yarrick v. Village of Kent City) 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
Yarrick v. Village of Kent City, 473 N.W.2d 774, 189 Mich. App. 627 (Mich. Ct. App. 1991).

Opinions

ON REMAND

Before: Holbrook, Jr., P.J., and Sawyer and Griffin, JJ.

Sawyer, J.

This matter, which involves the great marshmallow of the law, nuisance, is again before us for decision, having been remanded by the Supreme Court. 435 Mich 866; 457 NW2d 345 (1990). Plaintiff Nancy Yarrick was injured when she stepped in a small hole in a grassy area of a park maintained by defendant. Plaintiffs filed a complaint against defendant, arguing that their claim was not barred by governmental immunity [629]*629under the public building and intentional nuisance exceptions. The trial court granted summary disposition on the ground of governmental immunity. MCR 2.116(C)(7).

On appeal, we held that the public building exception was not applicable to the case at bar, but that the intentional nuisance exception was. 180 Mich App 410; 447 NW2d 803 (1989). Our opinion specifically concluded that intentional nuisance remained an exception to governmental immunity despite the Supreme Court’s decision in Hadfield v Oakland Co Drain Comm’r, 430 Mich 139; 422 NW2d 205 (1988). 180 Mich App 415.1 Thereafter, the Supreme Court vacated our judgment and remanded this matter to us for reconsideration in light of Li v Feldt (After Remand), 434 Mich 584; 456 NW2d 55 (1990), and for consideration of the existence and applicability of nuisance per se and public nuisance exceptions to governmental immunity.

Inasmuch as the Supreme Court ruled in Li (Añer Remand) that there is no intentional nuisance exception to governmental immunity, we need not give that issue further consideration. Rather, we must now turn our attention to the issues of public nuisance and nuisance per se exceptions to governmental immunity. We recently held that both public nuisance and nuisance per se are exceptions to governmental immunity. Li v Feldt (On Second Remand), 187 Mich App 457; 468 NW2d 268 (1991). In that opinion, we also held that raising the intentional nuisance issue was sufficient to preserve the issues of public nuisance and nuisance per se for this Court’s consideration. Id. at 478-479. Accordingly, we may [630]*630turn to the question whether the public nuisance and nuisance per se exceptions to governmental immunity are applicable to the case at bar.

Considering public nuisance first, plaintiff argues that the hole in which she stepped constitutes a public nuisance. While we do not believe that a hole in the ground always constitutes a public nuisance, we do agree that there are some circumstances under which it might. A public nuisance has been described as an act or omission "which obstructs or causes inconvenience or damage to the public in the exercise of rights common to all Her Majesty’s subjects.” Li (On Second Remand), supra at 488-489, quoting Prosser & Keeton, Torts (5th ed), § 90, pp 643-645. To some extent, a hole in the ground in a public park can cause inconvenience or damage to the public in the exercise of their right to use the park. However, as will be discussed infra, not all such holes would constitute a public nuisance, the distinction being whether the hole is naturally occurring or artificial.

Public nuisance is defined in 4 Restatement Torts, 2d, § 821B, p 87, as follows:

(1) A public nuisance is an unreasonable interference with a right common to the general public.
(2) Circumstances that may sustain a holding that an interference with a public right is unreasonable include the following:
(a) Whether the conduct involves a significant interference with the public health, the public safety, the public peace, the public comfort or the public convenience, or
(b) whether the conduct is proscribed by a statute, ordinance or administrative regulation, or
(c) whether the conduct is of a continuing nature or has produced a permanent or long-lasting effect, and, as the actor knows or has reason to know, has a significant effect upon the public right.

[631]*631As the Restatement suggests, the concept of public nuisance anticipates that the nuisance was created by human conduct, rather than being a naturally occurring condition. The Restatement further supports this conclusion when it discusses liability under nuisance for conditions occurring on land. Specifically, there may be liability for failure to abate an artificial condition on land, as explained at 4 Restatement Torts, 2d, § 839, p 161:

A possessor of land is subject to liability for a nuisance caused while he is in possession by an abatable artificial condition on the land, if the nuisance is otherwise actionable, and
(a) the possessor knows or should know of the condition and the nuisance or unreasonable risk of nuisance involved, and
(b) he knows or should know that it exists without the consent of those affected by it, and
(c) he has failed after a reasonable opportunity to take reasonable steps to abate the condition or to protect the affected persons against it.

The restriction of this rule is further explained in the accompanying comment:

The duty of a possessor of land under the rules stated in this Section does not exist in respect to most wholly natural conditions. (See § 840). [4 Restatement Torts, 2d, § 839, comment e, p 162.]

The principle that a naturally occurring condition is not a nuisance is further established in the Restatement in § 840:

(1) Except as stated in Subsection (2), a possessor of land is not liable to persons outside the land for a nuisance resulting solely from a natural condition of the land.
(2) A possessor of land who knows or has reason [632]*632to know that a public nuisance caused by natural conditions exists on his land near a public highway, is subject to liability for failure to exercise reasonable care to prevent an unreasonable risk of harm to persons using the highway. [4 Restatement Torts, 2d, § 840, p 166.]

The comment to §840 further clarifies that there is no duty to inspect for the purpose of discovering a dangerous natural condition:

There is no duty to inspect for the purpose of discovering a dangerous natural condition. [4 Restatement Torts, 2d, § 840, comment c, p 168.]

In light of this discussion of the Restatement, we conclude that, generally, there must be some human agency responsible for the creation of the condition which allegedly constitutes a public nuisance. Thus, if the hole in the ground in the case at bar was created by defendant, or one of its employees, or possibly even a user of the park, the hole might constitute a public nuisance. However, if the hole was naturally occurring, perhaps caused by a burrowing rodent, a public nuisance does not exist.

In looking at plaintiffs’ second amended complaint, their allegations for the most part center on defendant’s failure to inspect the grounds and discover and repair the hole. This is clearly insufficient to establish a public nuisance.

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Yarrick v. Village of Kent City
473 N.W.2d 774 (Michigan Court of Appeals, 1991)

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Bluebook (online)
473 N.W.2d 774, 189 Mich. App. 627, Counsel Stack Legal Research, https://law.counselstack.com/opinion/yarrick-v-village-of-kent-city-michctapp-1991.