Andy White and Amy White v. Targa Downstream, LLC, 358 So.3d 627

Andy White, an independent contractor for Ergon, loaded propane at Targa Downstream LLC’s Petal, MS facility using Targa‑owned loading hoses and valves.
Targa modified the hose valve from its original design by making the handle detachable and removing a locking device; Targa contended this made the equipment safer.
On January 14, 2017, while returning the hose to its resting tray after loading, the Targa hose valve opened and liquified propane spilled; White eventually replaced the detachable handle and closed the valve, later developing burns.
White sued Targa for negligence/premises liability, alleging Targa’s modification created a dangerous condition; White produced an expert report opining the modification contributed to inadvertent opening.
The trial court initially denied Targa’s first summary‑judgment motion (finding factual disputes about the modification and White’s knowledge), then granted a second summary‑judgment motion applying the "intimately connected" doctrine to bar recovery.
The Mississippi Supreme Court reversed and remanded, holding the doctrine does not immunize a premises owner when (1) the owner affirmatively created a dangerous condition and (2) there are genuine disputes about the owner’s creation of the danger and the contractor’s knowledge.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the intimately connected doctrine bars White’s premises‑liability claims	White: Targa created a latent dangerous condition by modifying the valve; the doctrine shouldn’t apply where owner created the danger and contractor lacked knowledge	Targa: Risk of spilling propane is inherent to loading work; doctrine bars recovery	Court: Doctrine does not apply where genuine issues exist that owner affirmatively created the danger and contractor’s knowledge is disputed — reverse and remand
Whether White knew or should have known of the valve modification (owner’s duty)	White: No evidence he knew the handle was modified or that risk increased	Targa: White, as an experienced loader, knew or should have known the risk	Court: Genuine issue of material fact exists as to White’s knowledge; cannot resolve on summary judgment
Whether no dangerous condition existed / expert proof was sufficient	White: Expert report (relied on by trial court) opined modification caused/contributed to inadvertent opening	Targa: Expert report was insufficient and not properly filed	Court: Trial court relied on the report to find a factual dispute; on appeal, Targa bore the burden to include the report in the record to challenge its sufficiency — genuine dispute remains

Peak v. Cohee, 294 So. 3d 604 (Miss. 2020) (recognizes intimately connected doctrine beyond repair but focuses on whether injury is linked to contracted work and plaintiff’s knowledge)
United Roofing & Siding Co. v. Seefeld, 222 So. 2d 406 (Miss. 1969) (adopts intimately connected doctrine barring owner duty for risks "arising out of or intimately connected with" work contractor undertook)
Magee v. Transcon. Gas Pipe Line Corp., 551 So. 2d 182 (Miss. 1989) (recognizes exception where owner retains substantial control over the dangerous aspect of work)
Oden Constr. Co. v. McPhail, 228 So. 2d 586 (Miss. 1969) (supplier/owner liable if it supplies chattel it knows or should know is dangerous and fails to warn)
Montedonico v. Mount Gillion Baptist Church, 64 So. 3d 1012 (Miss. Ct. App. 2011) (Court of Appeals reversed summary judgment where plaintiff was provided a defective instrumentality not inherent to the contractor’s work)
Jackson Ready‑Mix Concrete v. Sexton, 235 So. 2d 267 (Miss. 1970) (example where experienced contractor’s knowledge of inherent workplace risks justified applying the doctrine)