Court holds that landowner owes no duty, is not responsible for fall on "tilted porch"
In Ward v. Lowry, the plaintiff suffered elbow injuries when he fell while leaving the defendant's home. He had returned "cigarette rolling supplies" to the defendant when he tripped on uneven concrete on the rear "tilted" porch. The Court pointed out that under current Michigan law, the possessor of land owes no duty to address "open and obvious" dangers on the premises. Since Ward entered by this porch and was aware of its unsafe characteristics, he could not hold the landowner responsible for his injuries. Furthermore, the danger was not "unavoidable" as the home had two entrances.