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Darkness Falls: Dark Driveway Does Not Create Special Aspect

Premises Liability / November 3, 2017

In Garsoff v Dickerson, Plaintiff was an employee of Domino’s Pizza and was delivering pizza to Defendants’ home on February 28, 2014, at approximately 8 p.m. Plaintiff delivered pizza to the home on prior occasions as Defendants were regular customers of Domino’s. Plaintiff pulled into Defendants’ driveway and parked behind three vehicles. He recalled it being cold that evening, but he did not recall seeing snow on the ground. Plaintiff testified that the driveway was dark as all lights were off.

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