Valance v. VI-Doug, Inc.
Wyoming Supreme Court
50 P.3d 697 (2002)
On a windy wintery day, Jeanne Miles, age 75, opened the front door of a Village Inn Restaurant, owned and operated by VI-Doug, Inc. (VI-Doug) (defendant), when the wind forcefully caught the door and caused her to fall on the concrete walkway and break her hip. A sign posted on the door instructed customers to “Please Hold Door Tight Due to Wind.” Miles died two years later. Catherine Valance (plaintiff), as personal representative of Miles’s estate, filed suit against VI-Doug claiming the incident was caused by the company’s failure to provide a reasonably safe entryway for its patrons. VI-Doug moved for summary judgment, arguing that, under the open-and-obvious exception to a premises liability claim, a restaurant owes no duty to protect its customers from the effects of naturally-occurring wind. The trial court agreed, awarded summary judgment in favor of VI-Doug and further held that the restaurant did not violate its duty to maintain the premises in a reasonably safe condition because it placed the sign on the front door warning incoming customers of the potential danger. Valance appealed.
Rule of Law
Holding and Reasoning (Kite, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.
Here's why 175,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 14,000 briefs, keyed to 188 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.