Richardson v. Commodore, Inc.

599 N.W.2d 693 · Supreme Court of Iowa · 1999

Facts

Russell Richardson was injured at The Commodore Tap bar when a portion of the plaster ceiling fell on him while he was shooting pool. He sued the bar owners for premises liability, alleging negligence in maintaining the premises. The district court granted summary judgment for the defendants, which the court of appeals affirmed.

Issue

Did the district court err in granting summary judgment by concluding there was no evidence the bar owners knew or should have known of the dangerous ceiling condition, specifically regarding their duty to inspect for latent defects?

Holding

Yes, the district court erred. The Supreme Court vacated the court of appeals' decision, reversed the district court's judgment, and remanded the case, finding sufficient evidence to create a jury question on the premises liability claim.

Rule

A possessor of land is liable for harm to invitees from a condition if they knew or, by exercising reasonable care, would have discovered the condition and failed to protect against it. This duty of reasonable care includes inspecting for dangerous conditions, and the feasibility of inspection is a key factor in determining this duty.

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Case brief last reviewed 2026-01-08. Prepared by CaseReader from the published opinion.