Guilford v. Yale University
23 A.2d 917, 1942 Conn. LEXIS 143, 128 Conn. 449 (1942)
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Rule of Law:
A landowner's duty of reasonable care to an invitee extends to parts of the premises beyond the primary area of invitation if the landowner could reasonably foresee or contemplate that the invitee might use those areas.
Facts:
- Yale University assigned a building and its surrounding grounds to the class of 1936 for a reunion.
- It was customary for alumni from all classes to visit different reunion headquarters and to use the grounds as a general gathering place, a custom known to the university.
- The plaintiff, an alumnus from the class of 1899 attending his own reunion, visited the class of 1936 headquarters on the night of June 20, 1939.
- After socializing until 2 a.m., the plaintiff and others left the building, and the lights inside were turned off.
- While conversing on the sidewalk, the plaintiff decided to find a secluded place to urinate and walked from the sidewalk onto an adjacent grass plot.
- The area was shadowed, and the plaintiff mistook the top of a tree growing from a lower level for a bush on the grass plot.
- Walking towards what he thought was a bush, the plaintiff tripped over a low, unlit parapet at the edge of a retaining wall and fell approximately ten feet into a pit.
Procedural Posture:
- The plaintiff sued the defendant, Yale University, in a Connecticut trial court for negligence.
- The case was tried before a jury, which rendered a verdict in favor of the plaintiff.
- The defendant filed a motion to set aside the verdict.
- The trial court denied the defendant's motion.
- The defendant appealed the trial court's denial of its motion to the Supreme Court of Errors of Connecticut.
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Issue:
Does a landowner's duty of care to an invitee extend to protecting them from a danger on a portion of the premises that, while not a formal walkway, the landowner could reasonably contemplate the invitee would use given the nature and customs of the event?
Opinions:
Majority - Jennings, J.
Yes, a landowner's duty of care extends to areas they could reasonably contemplate an invitee would use. The plaintiff remained an invitee because his use of the premises was foreseeable under the circumstances. An invitation can be implied when a landowner prepares or allows a place to be used in a way that leads visitors to believe it is intended for their use. Given the 'open house, free and easy hospitality' customary during Yale's reunion period, the university could have reasonably anticipated that guests would use the grounds surrounding the reunion headquarters, not just the building and paved walkways. Therefore, the plaintiff did not exceed the scope of his invitation by stepping onto the grass plot. The university owed him a duty to exercise reasonable care to protect him from foreseeable dangers, and the unlit, unguarded retaining wall constituted a 'trap' for which the university could be found liable.
Analysis:
This decision broadens the scope of a landowner's duty in premises liability by adopting a flexible, foreseeability-based standard for determining the geographic limits of an invitation. It moves away from a rigid analysis of designated paths and instead focuses on what a landowner should reasonably contemplate a guest might do in a particular social context. The ruling establishes that customs and the nature of an event can expand the area where an invitee is owed a duty of care. This precedent requires landowners, especially those hosting social gatherings, to assess potential dangers on a wider portion of their property than just the immediate, intended areas of use.
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