Spears v. Blackwell

Brief Fact Summary.

Spears filed a negligence suit against Blackwell when Spears collided into an oncoming car in front of the Blackwell property.

Synopsis of Rule of Law.

A landowner does not owe a duty to citizens using the public road to protect them from harm from the natural conditions of the land.

Facts.

Spears was driving by the Blackwell property, and vegeatation by the property made it difficult for passersby to see clearly. Spears filed a negligence suit against Blackwell when Spears collided into an oncoming car in front of the Blackwell property. The trial court granted summary judgment to Blackwell.

Issue.

Whether a landowner owes a duty to citizens using the public road to protect them from harm from the natural conditions of the land?

Held.

No. The judgment of the trial court is reversed. The vegetation was not a natural condition because the Blackwells and their predecessor modified the land by planting shrubs and mowing the area. The Blackwells owed a duty to Spears.

Discussion.

A landowner does not owe a duty to citizens using the public road to protect them from harm from the natural conditions of the land. A condition of the land will not be considered a natural condition if it was changed by the act of the landowner or the landowner’s predecessor.