Valance v. VI-Doug, Inc.
Wyoming Supreme Court
50 P.3d 697 (2002)
Elderly patron Jeanne Miles broke her hip when high wind caught a restaurant door as she opened it, despite a sign reading "Please Hold Door Tight Due to Wind"; her estate representative Valance (plaintiff) sued VI-Doug (defendant), the restaurant owner, for failing to provide a reasonably safe entryway. The trial court granted VI-Doug summary judgment on the theory that wind is an open-and-obvious natural danger and that the warning sign satisfied any duty to maintain safe premises; Valance appealed.
Whether the open-and-obvious exception to a premises possessor's general duty of care insulates the proprietor from liability when a business invitee is injured by naturally occurring forces such as snow, ice, and wind.