## Facts

- Violet J. Moeller went to Holland Abundant Life Fellowship to attend a Bible study; she was not a church member.
- After parking in the church lot, Moeller exited a vehicle and tripped over a concrete tire stop, fracturing her left arm.
- Moeller and her husband sued the church for premises negligence, alleging improper placement of tire stops and inadequate parking-lot lighting.
- The trial court classified Moeller as a licensee, instructed the jury on licensee duties, and the jury returned a defense verdict.
- The intermediate appellate court reversed, holding Moeller was a “public invitee” and entitled to invitee instructions.
- The Michigan Supreme Court granted review to determine the correct standard of care owed to persons on church property for noncommercial purposes.

## Issues

1. Whether a person attending a church Bible study is a licensee or an invitee (including “public invitee”) for premises-liability purposes.
2. Whether premises held open to the public for noncommercial religious activities should trigger invitee status under Restatement (Second) of Torts § 332.
3. Whether the trial court’s jury instructions applying the licensee duty standard were erroneous.

## Decision

- The Michigan Supreme Court reversed the intermediate appellate court and reinstated the trial court’s judgment for the church.
- The Court held Moeller was a licensee because her presence was for a noncommercial religious purpose and did not confer a commercial/economic benefit on the church.
- The Court rejected the intermediate court’s use of Restatement § 332 to treat public access alone as sufficient to create invitee status.
- Because the trial court properly instructed the jury on the duty owed to licensees, the defense verdict stood.

## Legal Principles

- Michigan premises liability continues to apply entrant-status categories (trespasser, licensee, invitee), with duties varying by status.
- Invitee status generally depends on entry for a commercial purpose or circumstances indicating the possessor receives a tangible economic benefit; invitees are owed duties to warn, inspect, and make safe.
- Licensees are owed a limited duty: the possessor must warn of hidden dangers the possessor knows or has reason to know of, when the licensee does not know or have reason to know of the danger; there is no general duty to inspect or repair for licensees.
- Property being open to the public does not, by itself, convert entrants into invitees; “public invitee” concepts cannot be applied so broadly that they collapse the traditional categories.
- Persons entering church property for worship or religious study are ordinarily licensees absent a commercial or economic relationship tied to the visit.

## Conclusion

The court held that attendance at a church Bible study is a noncommercial use that makes the attendee a licensee, limiting the church’s duty to warning of known hidden hazards rather than imposing invitee-level obligations to inspect and make the premises safe.


Stitt v. Holland Abundant Life Fellowship, 462 Mich. 591, 614 N.W.2d 88 (Mich. 2000)