Madras v. Applebee's Neighborhood Grill & Bar

Citations

• 2025 Ohio 169

Syllabus

Slip and fall; premises liability; open and obvious; unnatural accumulation; black ice; summary judgment; actual or constructive notice. The judgment of the trial court, granting summary judgment in favor of defendant-appellee Apple Ohio LLC, is affirmed. The undisputed facts in the record indicate that the icy patch that plaintiff-appellant Madaras slipped on was an open-and-obvious condition that did not constitute an unnatural accumulation. Moreover, the record does not indicate that the patch of ice was \substantially more dangerous\ than Madaras should have reasonably anticipated, and even so, Applebee's did not have actual or constructive notice of such condition.