Byrd v. State

In Byrd v. State (1997) 50 Ill.Ct.Cl. 280, the Court considered whether the State had constructive notice of a dangerous condition where debris had collected on a stairway in the public aid building, In Byrd, a public aid applicant fell down steps when leaving the office, allegedly slipping on some debris that was on the stairs. The evidence established that the applicant had gone up the same set of stairs 20 minutes prior to her accident. The Court held that if the claimant failed to see the allegedly dangerous condition in such close proximity to the incident the State could not be held to have constructive knowledge. Id. At 285.