Ford v. Red Lion Inns

In Ford v. Red Lion Inns, 67 Wn. App. 766, 840 P.2d 198 (1992), Ford worked for a company that had contracted with the Red Lion to provide a designated parking area for its company vehicles. Id. at 768. The day of the incident, Ford noticed portions of the parking area were covered with ice, some were covered with snow and others were bare and wet. Id. While walking from his vehicle to another area in the parking lot to remove some barricades, he fell and was injured. Id. Ford brought suit against the Red Lion for negligence and when Red Lion sought summary judgment, Ford failed to present any evidence that Red Lion had breached its duty but relied only on the fact of accumulated ice and snow. Id. at 773. A possessor or owner of land generally is not liable to his invitees for physical harm caused to them by any activity or condition on the land whose danger is known or obvious to them. When grounding a claim on the exception provided by the Restatement (Second) of Torts 343 (1965), a claimant should be prepared to come forward with some evidence that the landowner failed to act reasonably under the circumstances. Ford, 67 Wn. App. at 773.