Campbell v. Weathers (1941) Case Brief: Kansas Supreme Court Ruling on Business Premises Liability

Citation

Campbell v. Weathers, 153 Kan. 316, 111 P.2d 72 (1941).

Court

Supreme Court of Kansas

Facts

The plaintiff, Campbell, entered the defendant's lunch counter, Weathers, without purchasing anything. He walked to the restroom located in the back of the premises, passed through a narrow hallway, and was injured when he fell through an open trapdoor in the floor. Campbell sued Weathers for negligence, alleging that Weathers failed to maintain safe premises for customers.

Issue

Whether the defendant owed a duty of care to the plaintiff, who had not made any purchases but was present on the premises.

Rule

A proprietor of a business establishment owes a duty of care to maintain the premises in a reasonably safe condition for customers and invitees.

Application

The court held that the plaintiff was a business invitee despite not making a purchase because his presence on the premises was implicitly connected to the business. The defendant had a duty to keep the premises reasonably safe for customers, including those who might not have made an immediate purchase. The narrow hallway and the open trapdoor were considered hazardous, and the failure to provide warnings or safeguards constituted a breach of duty.

Conclusion

The Supreme Court of Kansas found in favor of the plaintiff, Campbell. The court concluded that Weathers, the defendant, was negligent in maintaining an unsafe condition on the premises, which directly resulted in Campbell's injury.