Hall v. Cagle
773 So. 2d 928, 2000 WL 1429641 (2000)
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Rule of Law:
A person who enters another's property by express or implied invitation to perform a service that benefits the property owner may be classified as an invitee, to whom a duty of reasonable care is owed, even if the service is not for a commercial or business purpose.
Facts:
- Timothy and Beverly Cagle purchased a mobile home from Johnson Mobile Homes.
- Johnson Mobile Homes delivered the home and provided a set of temporary steps.
- Betty Hall went to the Cagles' home at their invitation to help them unload boxes and arrange furniture.
- Hall knew the temporary steps were shaky, and a Johnson employee had previously cautioned her to be careful on them.
- While leaving the mobile home by a back door, Hall lost her footing on the steps, fell, and sustained injuries.
Procedural Posture:
- Betty Hall sued Timothy Dale Cagle and Bill Johnson, d/b/a Johnson Mobile Homes, in the Lauderdale County Circuit Court (trial court) seeking damages for her injuries.
- The circuit court granted the defendants' motions for summary judgment, finding that Hall's legal status on the property was that of a 'licensee'.
- Hall, as appellant, appealed the summary judgment to the Mississippi Court of Appeals.
- The Court of Appeals affirmed the circuit court's judgment in favor of the Cagles and Johnson Mobile Homes (appellees).
- The Supreme Court of Mississippi granted Hall's petition for a writ of certiorari to review the lower courts' decisions.
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Issue:
Did the lower courts err in granting summary judgment by finding that a person injured while voluntarily helping a friend move is, as a matter of law, a licensee rather than an invitee?
Opinions:
Majority - Mills, J.
Yes. A person who is on the premises to render a service for the possessor's benefit may be classified as an invitee, creating a genuine issue of material fact that makes summary judgment improper. An invitee is not limited to one who enters for a business purpose. Citing Minor v. Engineering Serv. Co., the court held that a visitor can be an invitee if present for the benefit of the occupant. Because Betty Hall alleged she was on the property to perform a service for the Cagles' benefit (assisting with their move), she made a prima facie showing that she was an invitee, which is a question of fact for a jury to decide.
Concurring - McRae, J.
Yes, the lower courts erred, but the underlying legal framework of classifying visitors is flawed and should be abandoned in favor of a general negligence standard. The common law distinctions between invitee and licensee are archaic, confusing, and inconsistent with Mississippi's modern comparative negligence principles. The court should follow the modern trend, embraced by nearly half the states, of replacing these categories with a single duty of reasonable care owed to all lawful visitors, which would simplify the law and better serve justice.
Dissenting - Smith, J.
No. A person helping a friend move without compensation is a social guest and therefore a licensee as a matter of law, making summary judgment appropriate. Hall's own deposition testimony confirmed she was at the Cagle home as a friend and was not being paid. As a licensee, she assumed the ordinary risks of the premises, and the Cagles only owed her a duty to refrain from willful or wanton injury. Because Hall admitted she knew the steps were shaky, the Cagles breached no duty owed to her, and the trial court correctly granted summary judgment.
Analysis:
This decision significantly clarifies and potentially expands the category of 'invitee' in Mississippi premises liability law beyond the traditional commercial context. By recognizing that providing a beneficial, non-business service can confer invitee status, the court increases the duty of care homeowners owe to certain guests, blurring the line between social guests (licensees) and invitees. The influential concurring opinion also highlights a major jurisprudential debate, advocating for the abolition of the traditional premises liability categories, which could signal future shifts in Mississippi tort law toward a general negligence standard for all lawful visitors.
