## Facts

- Ronald and Mary Kinney, members of a church, hosted an early-morning Bible study at their home as part of a church-sponsored series.
- Jonathan Carter, also a church member, enrolled through a sign-up process limited to interested members; the event was not open to the general public.
- The night before the study, Ronald Kinney shoveled snow from the driveway but did not know ice formed overnight.
- Carter arrived shortly after 7:00 a.m., slipped on an icy patch in the driveway, and broke his leg.
- The Kinneys received no financial or other tangible benefit from Carter’s attendance, and the parties had no social relationship outside church activities.

## Issues

1. Whether Carter entered the Kinneys’ property as an invitee or a licensee for premises-liability purposes, and what duty was therefore owed.
2. Whether Missouri law had abandoned the traditional premises-liability categories (invitee/licensee) based on prior decisions.

## Decision

- The Supreme Court of Missouri (en banc) affirmed summary judgment for the Kinneys.
- Carter was a licensee, not an invitee, while attending the Bible study at the Kinneys’ home.
- Missouri continues to apply status-based premises-liability rules; prior cases did not eliminate the licensee–invitee distinction.
- Because the ice was an unknown hazard to the Kinneys, they owed no duty to discover or remedy it for a licensee.

## Legal Principles

- A social guest is a licensee; the possessor’s duty is to warn of or make safe known dangers that are not open and obvious, not to inspect for unknown hazards.
- An invitee generally enters by invitation connected to the possessor’s business or material benefit, or through an invitation to the general public implying reasonable safety.
- Intangible or mutual benefits associated with social or religious gatherings do not convert a licensee into an invitee.
- In Missouri, the land possessor’s duty of care in premises liability turns on the entrant’s status (e.g., invitee versus licensee).

## Conclusion

The court classified a church-member attendee at a home Bible study as a licensee and held the hosts had no duty to inspect for or remedy ice they did not know about, while reaffirming Missouri’s continued use of traditional entrant-status categories in premises-liability cases.


Carter v. Kinney, 896 S.W.2d 926 (Mo. 1995) (en banc)