Court Extends Invitee Status to Airbnb Guests and Raises Duty of Condominium Associations

In Letvin, the Michigan Court of Appeals continued to liberalize premises liability law, reiterating the Supreme Court’s decision in Janini v London Townhouses Condo Ass’n, 514 Mich 86 (2024), which allowed condominium owners to sue their condominium associations for injuries sustained in common areas. Letvin extended Janini to Airbnb renters, who can now sue their host’s condominium associations for injuries sustained in common areas. The Court determined that Plaintiff, who slipped and fell on ice in his Airbnb’s parking lot, was an invitee owed the highest duty of care and allowed the case to proceed to trial based solely on the presence of ice in the parking lot and the fact that none of the Defendant’s Board members took responsibility for the snow-removal contractor’s work.