Nolen v. State

In Nolen v. State (1983), 36 Ill. Ct. Cl. 194, Claimant was walking with a friend near the Stratton Building in Spring-field, and while walking across the patio approaching a door, she tripped over a handicapped ramp and injured her ankle. She testified the area was dark and she was unfamiliar with the area. State employees testified that they had not received any complaints concerning the sufficiency of the lighting in the area and there had been no complaints of injuries due to insufficient lighting or because of the existence of the handicapped ramp in the area. The Court held that the Claimant in Nolen was an invitee, and that the State had a duty to use reasonable care and warn its invitees of defects not readily apparent. The Court observed that the ramp had been in existence for sixteen years, that there had been no accidents, and that the State is not an insurer against accidents that may occur by reason of the condition of a State highway.