Stitt v. Holland Abundant Life Fellowship
614 N.W.2d 88 (2000)
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Rule of Law:
In Michigan, a person's status as an invitee on a property, which triggers the highest duty of care from the landowner, depends on the premises being held open for a commercial purpose. Individuals on church property for non-commercial purposes, such as attending a religious service, are classified as licensees.
Facts:
- On the evening of November 22, 1989, Violet Moeller accompanied a friend to a church to attend a bible study.
- Moeller was not a member of the church.
- Her friend parked her car in the church's parking lot.
- As Moeller exited the vehicle, she tripped and fell over a concrete tire stop.
- Moeller sustained a fractured left arm from the fall.
Procedural Posture:
- Violet Moeller filed a negligence lawsuit against the church in a Michigan trial court.
- The trial court ruled that Moeller was a licensee at the time of her injury.
- The judge instructed the jury based on the legal duties owed to a licensee.
- The jury returned a verdict in favor of the defendant church.
- Moeller, as the appellant, appealed the judgment to the Michigan Court of Appeals.
- The Court of Appeals, an intermediate appellate court, reversed, holding that Moeller was a 'public invitee' under the Restatement of Torts and remanded for a new trial.
- The church, as the appellant, was granted leave to appeal to the Michigan Supreme Court.
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Issue:
Does a person who enters church property for a non-commercial religious purpose qualify as an 'invitee' who is owed the highest duty of care under premises liability law?
Opinions:
Majority - Young, J.
No. A person who enters church property for a non-commercial purpose is a licensee, not an invitee. The court holds that invitee status must be directly tied to the owner's commercial business interests, as the prospect of pecuniary gain is a 'quid pro quo' for the higher duty of care. The court explicitly rejects the broader 'public invitee' definition from the Restatement (Second) of Torts, § 332, which does not require a commercial purpose. Attending church is for the visitor's spiritual benefit, not a material or commercial benefit to the landowner, and making voluntary donations does not alter this status. Therefore, the church owed Moeller the lesser duty of care applicable to a licensee, which is only to warn of known, hidden dangers.
Dissenting - Kelly, J.
Yes. A person on church property for a non-commercial purpose can qualify as a 'public invitee.' The dissent argues that Michigan common law has long recognized that invitee status is not based solely on economic benefit but also on the concept of a public invitation, consistent with the Restatement. The majority's decision to impose a strict commercial-purpose requirement is a departure from established precedent, particularly Preston v Sleziak, which the dissent believes implicitly adopted the Restatement view. Sound public policy supports imposing a duty of reasonable care on any property owner who opens their premises to the public, regardless of the purpose.
Analysis:
This decision significantly narrows the definition of an 'invitee' in Michigan premises liability law by rejecting the widely adopted 'public invitee' standard from the Restatement. By mandating a commercial purpose for invitee status, the court limits the highest duty of care to business-related contexts, thereby affording greater liability protection to non-profit and non-commercial entities that open their property to the public, such as churches, parks, and community centers. This ruling creates a clear doctrinal split from the majority of jurisdictions and makes it substantially more difficult for individuals injured on non-commercial properties to succeed in negligence claims.
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