Evans v. Hodge
Mississippi Court of Appeals
2 So. 3d 683 (2008)
Dianne Evans (plaintiff), Bonnie Hodge (defendant), and Betty Russell were college friends; Hodge and Russell were also sisters. After Russell's house burned down, she temporarily moved into Hodge's home. Evans regularly collected Russell's mail and, at Russell's request, brought it to Hodge's house, where Evans slipped on an icy doormat and was injured. Evans sued Hodge for negligence, claiming invitee status; Hodge argued Evans was merely a licensee owed a lesser duty. The trial court agreed with Hodge and granted summary judgment without ever deciding what status Russell herself held while staying there. Evans appealed.
Whether an invitee of a landowner may pass on her invitee status to another person who visits the property for the invitee's benefit.