Paula Henderson v. New Wineskin Ministries Corporation, 160 N.E.3d 582

On Jan. 29, 2017, Paula Henderson attended morning service at New Wineskin Ministries and parked in a handicap space directly in front of the church.
It was snowing with about two inches of accumulation; the parking lot was untreated and covered in visible snow and ice.
After being warned by her son that it was slippery, Henderson exited the car, took two steps, slipped, and injured her shoulder, back, and neck.
Henderson sued New Wineskin for negligence; the church moved for summary judgment relying on Ind. Code § 34-31-7-2, which limits nonprofit religious organizations’ duties to invitees to (1) warning of hidden dangers (if the organization has actual knowledge) and (2) refraining from intentional harm.
The trial court granted summary judgment, finding the hazard (snow/ice) was not hidden because it was visible and Henderson knew of snow/ice; the Court of Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a church parking lot is part of the statutory term “premises” in I.C. § 34-31-7-2	"Premises" should be read to mean building space; § 34-31-7-3 defines premises as part of a building, so § 34-31-7-2 should likewise be limited	The statute does not define "premises" in § 34-31-7-2; ordinary meaning (building plus grounds) includes parking lots; the § 34-31-7-3 definition applies only to that section	Court held "premises" includes parking lots; § 34-31-7-2 applies
Whether the snow/ice that caused Henderson’s fall was a “hidden danger” such that the church had a duty to warn (and thus whether a duty was breached)	Henderson lacked a specific appreciation of slipperiness until after stepping out of the car, creating a factual dispute over whether the danger was hidden	Snow and ice were visible and obvious; objective evidence shows danger was not hidden, so no statutory duty to warn was triggered	Court held the snow/ice was not a hidden danger as a matter of undisputed fact; no breach under § 34-31-7-2

Hughley v. State, 15 N.E.3d 1000 (Ind. 2014) (standard of review for summary judgment)
Kramer v. Catholic Charities of Diocese of Fort Wayne-S. Bend, Inc., 32 N.E.3d 227 (Ind. 2015) (negligence cases are fact-sensitive and summary judgment is rarely appropriate)
Certa v. Steak ‘n Shake Operations Inc., 102 N.E.3d 336 (Ind. Ct. App. 2018) (parking lots can be part of the premises for premises-liability duties)
Lutheran Hosp. of Ind., Inc. v. Blaser, 634 N.E.2d 864 (Ind. Ct. App. 1994) (use of parking lot can affect invitee risk)
Ind. Ins. Co. v. Dreiman, 804 N.E.2d 815 (Ind. Ct. App. 2004) ("premises" is unambiguous)
Rainbow Realty Group, Inc. v. Carter, 131 N.E.3d 168 (Ind. 2019) (declines to import a definition from another statutory section)
Montgomery v. State, 878 N.E.2d 262 (Ind. Ct. App. 2007) (give undefined statutory terms their common and ordinary meaning)
Miller v. Rosehill Hotels, LLC, 45 N.E.3d 15 (Ind. Ct. App. 2015) (distinguishable case where invitee status imposed broader duties)