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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.)

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