Hospital owes no special duty to consider ambulatory abilities of patients
Constance Jedrzejas sued the Genesys Regional Medical Center after her husband, Ronald, tripped and fell on his way to dialysis. Ronald later died and Constance argued that the design of the Medical Center, with a stone slab trip hazard around a blind corner, presented an unreasonable risk to patients. The Court of Appeals upheld the dismissal of the Jedrzejas' lawsuit, holding that under Michigan law, a landowner need only design for "average persons of ordinary intelligence." The presence of a patient population having special needs or disabilities does not change the landowner's duty under Michigan law.