Speculation Does Not Establish Notice

Bowers reinforces that, even after Kandil-Elsayed, plaintiffs must still produce evidence establishing notice and causation. General winter conditions and speculation regarding when ice formed remain insufficient to survive summary disposition.

The decision also confirms that MCL 554.139 continues to provide limited application to residential tenants. A localized icy condition does not render a parking lot unfit for its intended use absent evidence that the condition prevented ordinary use of the common area.