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Machado v. Yacht Haven U.S.V.I., LLC

Supreme Court of Virgin Islands
61 V.I. 373 (2014)


Facts

Yacht Haven U.S.V.I., LLC (defendant) owned a shopping complex accompanied by a parking lot. The parking lot contained a median parallel to the storefronts, dividing the two parking rows closest to the storefronts. In order to get to the further row, patrons and employees either had to walk the length of the parking lot to go around the median, or walk over the median. It was common practice for patrons and employees to walk over the median. Yacht Haven was aware of this practice, but did not have a policy against the practice, and there were no signs warning individuals about the median. Elissa Machado (plaintiff), an employee at one of the stores, walked over the median to get to her car and tripped on a sprinkler head, breaking her leg. Machado brought a negligence suit against Yacht Haven. The superior court granted Yacht Haven summary judgment, finding that it owed no duty to Machado under the traditional trichotomy jurisprudence, which categorized an entrant onto land as an invitee, license, or trespasser. Machado appealed.

Rule of Law

Issue

Holding and Reasoning (Cabret, J.)

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