Ironwood Springs Christian Ranch, Inc. v. Emmaus, 801 N.W.2d 193

Ironwood Springs Christian Ranch, Inc. owned and operated a retreat facility; Emmaus rented part of Ironwood for a weekend retreat in January 2005.
Ironwood staff remained on site and performed ongoing maintenance; Rottinger, Emmaus’s retreat supervisor, supervised the weekend.
Ice formed outside the dining hall door from roof melt; Salt and ice chisel were located; Rottinger salted and chopped ice four to five times, while Ironwood staff allegedly treated the ice at times.
Retreat participant Jacky Larkin slipped on the ice, sustaining serious injuries; a jury allocated damages with Ironwood bearing 58% and Larkin 42% fault.
Ironwood sued Emmaus for contribution; Emmaus moved for summary judgment arguing no duty owed because Emmaus did not possess the land and did not assume Ironwood’s duty.
District court granted summary judgment for Emmaus; on appeal, the court reverses in part and remands for trial on whether Emmaus assumed Ironwood’s duty under Restatement (Second) of Torts § 324A.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is Emmaus a land possessor with a duty to Larkin?	Larkin argues Emmaus, by controlling retreat activities, owed the same duty as Ironwood.	Emmaus did not occupy or control the premises; Ironwood remained in control and had duty.	Emmaus not a possessor; no duty identical to Ironwood.
Did Emmaus assume Ironwood’s duty under Restatement § 324A and is there material fact about reliance?	Emmaus assumed Ironwood’s duty to address the ice; reliance by Ironwood and Larkin could exist.	There was no notional complete assumption of Ironwood’s duty; disputed facts about scope and reliance.	Material facts exist; summary judgment improper; remand for trial on sections 324A(a), (b), (c).

Isler v. Burman, 305 Minn. 288, 232 N.W.2d 821 (Minn. 1975) (defines possessor duties under factual approach)
Sutherland v. Barton, 570 N.W.2d 1, 7 (Minn. 1997) (landowners owe reasonable care to invitees)
Dishington v. A.W. Kuettel & Sons, Inc., 255 Minn. 325, 96 N.W.2d 684 (Minn. 1959) (control of premises imposes owner-like duty)
Abresch v. Northwestern Bell Tel. Co., 246 Minn. 408, 75 N.W.2d 206 (Minn. 1956) (restatement § 324A concepts and reliance-based liability)
Pagra v. City of Richfield (Walsh v. Pagra Air Taxi, Inc.), 282 N.W.2d 567 (Minn. 1979) (distinguishes § 323 vs § 324A applicability for undertakings)
Erickson v. Curtis Inv. Co., 447 N.W.2d 165 (Minn. 1989) (security undertakings may create duty to third parties under § 324A(b))
Bjerke v. Johnson, 742 N.W.2d 660 (Minn. 2007) (discussion of complete assumption standard under § 324A)
Cracraft v. City of St. Louis Park, 279 N.W.2d 801 (Minn. 1979) (a duty to avoid increasing risk; context for § 324A(a))
Andrade v. Ellefson, 391 N.W.2d 836 (Minn. 1986) (limits on duty when intervention fails to decrease risk under § 324A(a))
Walsh v. Pagra Air Taxi, Inc., 282 N.W.2d 567 (Minn. 1979) (illustrates § 324A vs § 323 analysis for undertakings)
Paidar v. Hughes, 615 N.W.2d 276 (Minn. 2000) (causation generally fact-intensive in negligence cases)
Williams v. Hams, 518 N.W.2d 864 (Minn.App. 1994) (reliance element in voluntary duty contexts)