Wintertime in Michigan: Appellate court finds that black ice can be open and obvious even where the ice itself is not visible on casual inspection

In Duff, the Plaintiff was injured when he slipped and fell on black ice while walking on an asphalt driveway at a campground where he lived and worked. Plaintiff sued the campground owner for negligence under theories of premises liability and violation of a landlord’s statutory duty to keep common areas fit for their intended use, MCL 554.139.

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