Bullard v. Oakwood Annapolis Hospital

I. INTRODUCTION

This case stems from a slip and fall accident. Flaintiff, Bruce Bullard, Jr. (Bullard), slipped on ice that formed on a wood plank on the roof at defendant Oakwood Annapolis Hospital (Oakwood). Under Michigan caselaw, ice is an “open and obvious” hazard. Open and obvious hazards cannot give rise to liability unless they cause an accident that involves “special aspects.” Specifically, a hazard might have special aspects that give rise to liability if the hazard is (1) “unreasonably dangerous” in and of itself, or (2) “effectively unavoidable” for the plaintiff.

The trial court…