Worker's Fall in Icy Parking Lot Can Be Deemed 'Effectively Unavoidable'

The Michigan Supreme Court ruled that an open and obvious condition can be deemed effectively unavoidable when a plaintiff must confront it to enter her place of employment. Case: Estate of Livings v. Sage’s Investment Group LLC, No. 159692, 06/30/2021, published. Facts: On Feb. 21, 2014, Donna Livings pulled into the parking lot at her workplace, Grand Dimitre's of Eastpointe Family Dining. Grand Dimitre’s leased the space from Sage's Investment Group LLC. Livings chose the closest space not covered with snow, about 70 feet from the back door. According to Livings...