Christopher Henkel and Lisa Henkel v. Christopher Norman, 441 S.W.3d 249

Mail carrier Christopher Norman slipped and fell on the Henkels’ sidewalk on January 9, 2010, during unusually cold weather with a hard-freeze warning in effect.
Norman delivered mail to Lisa Henkel, who, as he left, told him “don’t slip” (he later testified to that wording; Lisa in deposition said “be careful. It’s icy out there today”).
Norman sued, alleging the Henkels knew of ice on the sidewalk and failed to remove it or warn him adequately.
The Henkels moved for summary judgment, arguing Lisa’s verbal warning conclusively negated negligence by adequately warning Norman.
The trial court granted summary judgment for the Henkels; the court of appeals reversed, holding a general warning like “don’t slip” is not conclusively adequate.
The Texas Supreme Court reviewed de novo and held Lisa’s remark, viewed in context (freezing temperatures, knowledge of neighborhood ice), was an adequate warning as a matter of law and reversed the court of appeals, remanding for consideration of other issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a homeowner’s verbal warning (“don’t slip”) is an adequate warning as a matter of law to discharge duty to invitee	Norman: the warning was general/non‑specific and inadequate; owner must warn of the particular hazard (ice)	Henkels: Lisa’s statement warned of the hazardous condition and conclusively negates negligence	Court: "don’t slip," taken in totality (freezing conditions, context), conveyed a slippery condition and was adequate as a matter of law
Whether warning must identify the specific substance causing slipperiness (ice)	Norman: warning was too vague because many things can cause a slip; must identify ice	Henkels: need only convey the dangerous condition (slippery surface), not the exact substance	Court: owner need not name the exact material; warning of the condition itself suffices if a reasonable person would understand it

Buck v. Palmer, 381 S.W.3d 525 (Tex. 2012) (summary‑judgment standard on appeal)
Frost Nat’l Bank v. Hernandez, 315 S.W.3d 494 (Tex. 2009) (traditional summary judgment requires negating an element)
TXI Operations, L.P. v. Perry, 278 S.W.3d 763 (Tex. 2009) (warning must inform invitee of the particular dangerous condition)
CMH Homes, Inc. v. Daenen, 15 S.W.3d 97 (Tex. 2000) (elements of a premises‑liability claim)
Bill’s Dollar Store, Inc. v. Bean, 77 S.W.3d 367 (Tex. App.—Houston [14th Dist.] 2002) (verbal warning to "watch the wet spot" adequate as a matter of law)
Brooks v. PRH Invs., Inc., 303 S.W.3d 920 (Tex. App.—Texarkana 2010) (wet‑floor sign plus verbal warning adequate as a matter of law)
Keetch v. Kroger, 845 S.W.2d 262 (Tex. 1992) (references dangerous condition as the "slippery spot")