Who Invited Them? An Invitation by the Land Possessor is a Prerequisite to Invitee Status

The Michigan Court of Appeals in Alexis v Cerroni, an unpublished opinion issued on February 11, 2026 (Docket No. 373117), clarified that in the context of premises liability law in Michigan, for a claimant to be considered an invitee, the claimant must show that they were invited on the defendant land possessor’s property by the defendant land possessor. An invitation by someone other than the defendant land possessor is therefore insufficient for a claimant to benefit from invitee status, regardless of whether or not the claimant’s presence on the defendant land possessor’s property was the result of some pecuniary benefit.