## Facts

- Valerie Koenig visited her son, Marc Koenig, at his home to care for him while he was ill and to help with household chores.
- While doing laundry, Valerie tripped and fell over a carpet-cleaner hose while carrying clothes to a bedroom.
- Valerie suffered leg injuries requiring medical treatment, including placement of a plate in her leg.
- Valerie sued Marc for negligence, seeking damages for permanent injury, pain and suffering, and medical expenses; Marc denied negligence and asserted comparative fault and failure to mitigate.
- Valerie presented evidence that Marc knew the hose was broken and did not warn her, that the hose blended with the carpet, and that a hallway light near the fall was not working.
- Marc presented evidence that the hazard was open and obvious and that Valerie did not turn on the working hallway light.

## Issues

1. Whether Iowa should retain the common-law invitee/licensee distinction in premises-liability cases.
2. Whether land possessors owe entrants a general duty of reasonable care under the circumstances instead of status-based duties.
3. Whether the trial court erred by instructing the jury using a licensee premises-liability instruction rather than a general negligence instruction, requiring a new trial.

## Decision

- The Iowa Supreme Court abandoned the common-law distinction between invitees and licensees in premises-liability cases.
- The court held that possessors of land owe a general duty to exercise reasonable care under all the circumstances to entrants (other than categories not at issue in the case).
- The court concluded that the district court’s use of a licensee-based instruction applied an incorrect duty standard.
- The judgment for Marc was reversed, and the case was remanded for a new trial under the general negligence framework.

## Legal Principles

- Premises-liability claims are governed by ordinary negligence principles, with duty measured by reasonable care under the circumstances rather than by the entrant’s status as invitee or licensee.
- The reasonableness inquiry focuses on negligence factors such as foreseeability of harm, the probability and gravity of harm, and the burden of precautions.
- Status-based categories can improperly divert attention from factual assessments of risk and reasonable conduct; jury instructions must reflect the unified reasonable-care standard.

## Conclusion

The court replaced Iowa’s invitee/licensee premises-liability framework with a single reasonable-care duty and ordered a new trial because the jury was instructed under a now-rejected licensee standard rather than general negligence.


Koenig v. Koenig, 766 N.W.2d 635 (Iowa 2009)