Whaley v. Lawing

Summary

The Alabama Supreme Court affirmed a directed verdict for homeowners in a premises-liability action arising from the collapse of a redwood sundeck that injured a social guest. The court held that the evidence did not support a reasonable inference that the homeowners knew of the deck's dangerous condition and acted wantonly, and it upheld exclusion of prior pleadings against the contractor because no inconsistency concerning the sundeck was shown.

Holdings

1. The traditional classifications of trespasser, licensee, and invitee remain viable under Alabama law.
2. The trial court did not err in excluding the prior complaint because the plaintiff could not provide evidence linking that complaint to the sundeck and therefore could not show an inconsistency with the defendants' position that they lacked knowledge of a defective sundeck.
3. The directed verdict for the defendants was proper because the evidence did not support a reasonable inference that the defendants knew the sundeck was defectively and dangerously constructed or that its condition was likely to cause collapse.

Questions Presented

1. Whether Alabama should abolish the traditional trespasser, licensee, and invitee classifications in premises-liability cases.
2. Whether the trial court erred by excluding the defendants' prior complaint against the contractor as evidence of their knowledge of the sundeck's defective condition.
3. Whether the evidence presented a scintilla supporting the plaintiff's claim that the defendants acted wantonly by allowing him to use a sundeck they knew was unstable and dangerous.

Disposition

affirmed