Woman who fell on oil slick in church parking lot cannot pursue injury claim
Brenda Sanders was on her way to attend a worship service and have lunch in the Perfecting Church Cafe when she fell and was injured. She argued that she was an "invitee" to the church and that it therefore owed her a reasonable duty to discover and remediate the oil slick in the parking lot.
Several years ago, Michigan's insurance-oriented Republican majority changed Michigan law to hold that persons attending church are not "invitees" and therefore the church owes no duty to inspect its premises and discover dangerous conditions that could cause injury. In Sanders' case, the Court of Appeals relied upon these decisions to hold that even ancillary "commercial" visits--like buying lunch at the church cafe---do not make the visitor an invitee and do not create a duty on the part of the church.
Therefore, basically, the church's duty to act as a reasonable property inviting the public to visit is eliminated. Its duty is basically limited to eliminated extremely hazardous conditions which it actually knows to exist and which would not be "apparent on casual inspection to a visitor."