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Once Bitten, Twice Shy: Court of Appeals Finds Questions of Fact Whether Hotel was Negligent in Maintaining Safe Accommodations After Guest’s Brown Recluse Bite

Premises Liability / June 18, 2019

In Heuschneider v Wolverine Superior Hospitality, Inc. d/b/a Comfort Inn & Suites, unpublished opinion per curiam of the Court of Appeals, issued June 4, 2019 (Docket No. 341053), the Court considered whether a hotel breached its duty when a guest was bitten and seriously injured by a brown recluse spider. While most guests may encounter more mundane pests, the innkeeper’s duty is to protect its guests from all vermin, whether their presence has been detected or not. Whether the pests are mundane and visible or venomous and unknown, the Court’s decision in Heuschneider, although unpublished, should cause innkeepers some pause and prompt reconsideration of how seriously they attend to pest management.

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