Court reaffirms that churches owe no duty to discover hazardous conditions before inviting public entry

Under the common law in Michigan, up until about 15 years ago, persons who entered a church property were deemed "invitees."  As such, the church held open to the public owed them a duty to take reasonable steps to discover and correct any hazardous conditions on the property.  When Governor Engler was able to select a majority of the Michigan Supreme Court's Republican Justices, his court over-turned this rule and held that only "commercial" landowners owed a duty of reasonable care to "invitees:"  it was deemed that churches merely tolerated vistors (or "licensees") and that they owed no duty beyond correcting known-but hidden-dangers.

In the recent case of Brenda Sanders v. Perfecting Church, the Court of Appeals reaffirmed the limited duty of any non-commercial landowner.  Sanders fell on motor oil in the parking lot and suffered severe fractures in her arm and wrist.  The Court upheld the summary disposition of her claim because the church owed no duty to find or eliminate the hazardous spill or to make church property safe, and Sanders couldn't prove that the church had prior knowledge of the spill.