Raflo v. The Losantiville Country Club

In Raflo v. The Losantiville Country Club (1973), 34 Ohio St.2d 1, 295 N.E.2d 202, the plaintiff entered and exited a country club by the same door and in so doing traversed a step located at the door. The plaintiff fell as she was attempting to negotiate the step as she left the country club. The Supreme Court of Ohio, in applying its previous holding in Leighton, held: "Generally, the plaintiff's failure to avoid a known peril is not excused by the fact that he 'did not think' or 'forgot.'" Id. at 3. In upholding the trial court's award of summary judgment to the country club, the Court held that an "invitee with knowledge of a step at an exit door traverses it at his own peril." Id. at 4.