Carter v. Kinney
Supreme Court of Missouri
896 S.W.2d 926 (1995)
Carter (plaintiff) slipped on ice that formed overnight in the driveway of the Kinneys (defendants), whom he was visiting to attend a private bible study limited to church members who had signed up in advance, with no general public invitation and no material benefit flowing to the Kinneys from hosting. The Kinneys had cleared snow the day before but didn't know ice had since formed; the trial court granted them summary judgment, finding Carter was merely a licensee owed no duty regarding unknown dangers, and Carter appealed, arguing he was an invitee owed a broader duty.
Whether a landowner owes a duty to protect an entrant from unknown dangerous conditions when the entrant is a social guest invited to a private gathering, without a general public invitation or expectation of material benefit to the landowner.