Pinnell v. Bates
2002 WL 2027335, 838 So.2d 198 (2002)
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Rule of Law:
A social guest who provides a tangible benefit to a landowner may be considered an invitee, creating a question of fact for a jury as to their legal status and the corresponding duty of care owed by the landowner.
Facts:
- Patsy Bates was in the process of moving into her new house.
- Bates invited her friend, Shirley Annette Pinnell, to visit.
- Pinnell arrived in the afternoon and, during her visit, helped Bates with cleaning and unpacking because Bates was having back trouble.
- At approximately 9:00 p.m., while exiting the front door, Pinnell fell from the concrete steps onto the porch.
- As a result of the fall, Pinnell broke a finger and her leg.
Procedural Posture:
- Shirley Annette Pinnell filed a negligence complaint against Patsy Bates in the Circuit Court of Jefferson Davis County, a trial court.
- Bates filed a motion for summary judgment, asserting Pinnell was a licensee and that Bates had not engaged in willful or wanton conduct.
- The circuit court granted summary judgment in favor of Bates, finding as a matter of law that Pinnell was a licensee.
- Pinnell, as appellant, appealed the trial court's grant of summary judgment to the Supreme Court of Mississippi.
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Issue:
Does a social guest who performs services for a homeowner's benefit, such as helping unpack and clean, create a jury question as to whether they are an invitee rather than a licensee for the purposes of premises liability?
Opinions:
Majority - Waller, J.
Yes, a factual dispute exists as to the licensee/invitee status of Pinnell. While the court declines to abolish the common law distinctions between licensees and invitees, precedent establishes that a visitor may become an invitee if they are on the premises for the occupant's benefit, even if not for a business purpose. Because Pinnell performed services for Bates's benefit by helping her unpack and clean, a jury question was created as to whether she was an invitee. Therefore, granting summary judgment was improper.
Dissenting - McRae, P.J.
The dissent argues that the underlying legal question is flawed and that the court should abolish the archaic common law distinctions between licensee and invitee. Instead of analyzing Pinnell's status, the court should have adopted a single standard of 'reasonable care under the circumstances' for all premises liability cases. This standard would be flexible enough to account for the differences between a homeowner and a commercial enterprise. The dissent contends that since the judiciary created these 'feudalistic' classifications, it has the inherent power to abolish them without legislative action.
Analysis:
This decision reaffirms Mississippi's adherence to the traditional common law classifications of entrants on land (invitee, licensee, trespasser) while many other jurisdictions were moving towards a single standard of reasonable care. However, the ruling significantly clarifies the 'invitee' category by holding that a material, non-business benefit conferred by a social guest upon the landowner can elevate the guest's status to that of an invitee. This creates a more fact-intensive inquiry for trial courts, making it more difficult for landowners to obtain summary judgment when a social guest who was providing assistance is injured on their property.
