Miller v. Grewal Bros. Corp., 2012 Ohio 1279

Miller sued Grewal for injuries from a slip at the Best Western Napoleon Inn under a canopy on Jan 30, 2009.
Weather that day was cold with intermittent snowfall; area under the canopy was exposed on three sides.
Miller slipped while collecting luggage from a vehicle parked under the canopy; others observed ice nearby.
Hotel staff and Miller noticed ice conditions; clerks reported it was slick and salt should have been applied.
Balraj Grewal inspected the area later and did not observe ice; photos were taken at ~11:00 p.m.; Jagdev Grewal also inspected and found no ice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the ice was a natural accumulation rather than an abnormal one	Miller argues the ice was non-natural and thus Grewal owed a duty	Grewal contends the ice was a natural accumulation with no duty to remove	Natural accumulation; no duty owed to Miller
Whether Grewal had superior knowledge of the ice to create a duty to warn/remove	Miller asserts Grewal knew or should have known of a danger	Grewal had no superior knowledge; area under canopy open to elements	No superior knowledge; equal knowledge; no duty established

Paschal v. Rite Aid Pharmacy, Inc., 18 Ohio St.3d 203 (1985) (owner owes no duty to remove natural ice/snow dangers)
Brinkman v. Ross, 68 Ohio St.3d 82 (1993) (natural accumulations generally not a duty to remove or warn)
Debie v. Cochran Pharmacy-Berwick, Inc., 11 Ohio St.2d 38 (1967) (exception for known dangerous conditions from natural accumulations)
Sidle v. Humphrey, 13 Ohio St.2d 45 (1968) (open and obvious dangers from natural accumulations)
Mikula v. Slavin Tailors, 24 Ohio St.2d 48 (1970) (equal knowledge extinguishes duty when dangers are open and obvious)
Lapatkovich v. City of Tiffin, 28 Ohio St.3d 204 (1986) (active negligence to create/permit an unnatural accumulation)