“Abundant Snow” Present When Plaintiff Fell Renders Danger of Ice “Open and Obvious”

On December 7, 2010, the Michigan Court of Appeals released its unpublished opinion in Torrez v Goodwill Industries, No. 292138. In this timely opinion – released just days before an early December snowstorm that was remarkable even by Michigan’s standards – the court held that the Plaintiff’s “black ice” slip and fall claim was properly dismissed under the “open and obvious” doctrine….