Airline passenger, who was invitee at city airport, brought negligence action against city and city’s parking contractor arising from passenger’s slip and fall on patch of ice that allegedly was created by an unknown traveler’s dump of beverage in airport’s passenger unloading zone in winter.
The Fourth Judicial District Court granted summary judgment for city and contractor. Passenger appealed.
The Supreme Court held that:
- Ice patch was an isolated incident rather than a recurring condition resulting from airport’s operating methods;
- There was no evidence that city and contractor had actual or constructive knowledge of ice patch; and
- Trial court did not improperly sua sponte decide issue of causation.