Larrieu v. Best Buy Stores, L.P., 303 P.3d 558

Larrieu and his daughter went to a Best Buy warehouse to pick up a purchased freezer.
Best Buy employee Stanley Monroe helped unload a heavy tailgate; Larrieu carried one end while the employee facilitated the other.
Larrieu tripped over a curb as the tailgate was moved toward him, causing a compression fracture.
Larrieu sued Best Buy in state court for injuries under Colorado's premises liability statute; the case was removed to federal court on diversity grounds.
The district court granted summary judgment, holding the statute applies only to activities inherently related to the land; the Tenth Circuit certified the question to the Colorado Supreme Court, reformulated as whether the statute applies only to directly or inherently related activities.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the premises liability statute applies only to directly related activities	Best Buy argues restriction to direct land-related activities	Best Buy contends the statute should be read narrowly to inherently land-related activities	No; statute not limited to directly related activities.
Whether the statute covers injuries caused by a landowner's employee on the property	Larrieu argues employee activity on property falls within the statute	Best Buy argues limitations should apply to land-related activities	Yes; statute applies to injuries caused by landowner activities on the property.
How to interpret 'activities conducted or circumstances existing on such property' under Pierson and related precedent	Larrieu's interpretation should extend to landowner-performed activities on property	Lar-rieu's view would render statute overly broad	Statute applies to activities/conditions the landowner is legally conducting or creating on the property; case-by-case factual inquiry required.

Pierson v. Black Canyon Aggregates, Inc., 48 P.3d 1215 (Colo. 2002) (landowner includes those legally conducting activities on property; limits scope to landowner responsibility on property)
Trailside Townhome Ass'n, Inc. v. Acierno, 880 P.2d 1197 (Colo. 1994) (premises liability delineates duties by landowner to entrants; does not apply where right to use property independent of consent)
Vigil v. Franklin, 103 P.3d 322 (Colo. 2004) (statutory construction; legislature adopted common-law trespasser/licensee/invitee framework; statutory definitions guide duties)
Lakeview Assocs., Ltd. v. Maes, 907 P.2d 580 (Colo. 1995) (common-area duties under premises liability; tenant inclusion and related considerations)
Wilson v. Marchiondo, 124 P.3d 837 (Colo. 2007) (actual knowledge standard for licensees under premises liability; heightened knowledge requirement)
Pierson v. Black Canyon Aggregates, Inc., 48 P.3d 1215 (Colo. 2002) (central Pierson holding reconciling landowner liability scope with statutory language)