Willard v. Dore

Plaintiff Leona Willard, a farm worker, was injured while picking apples when she fell off a 16-foot ladder provided by defendant, Gayle M. Dore. Plaintiff claimed that defendant was negligent in not determining if the ladder was unsafe. The jury found for plaintiff in the amount of $10,000. Defendant appeals as of right.

Defendant contends that the trial court erred in not granting his motion for directed verdict based on the applicability of the simple-tool doctrine. The rationale of the simple-tool doctrine was stated in Rule v Giuglio, 304 Mich 73, 79-80 (1942):

"The next and most serious…