Dupuis v. Eastern Idaho Health Services Inc.Annotate this Case
This case presented the Idaho Supreme Court with a fundamental, but previously unanswered, question: what duty is owed by a hospital to someone who is on its premises solely to visit one of its patients? Summary judgment was entered against Victor Dupuis in a premises liability case brought against a hospital, Eastern Idaho Regional Medical Center. Dupuis was visiting his hospitalized wife in January 2017 when he slipped and fell on ice in the hospital’s parking lot. Dupuis sued the hospital, alleging inadequate snow and ice removal in the parking lot caused him to fall. Dupuis argued that the hospital had breached the duty of care it owed to him as an invitee. The district court granted the hospital’s motion for summary judgment, holding that Dupuis was a licensee, and the hospital did not have superior knowledge of the dangerous conditions over that of Dupuis, and, therefore, the hospital did not breach any duty owed to Dupuis. Dupuis appealed, arguing the district court erred in determining that he was a mere licensee, rather than an invitee, and that even if he were a licensee, the hospital assumed and subsequently breached a duty of care to keep the property in reasonably safe condition. The Supreme Court found Dupuis was an invitee, thereby reversing the district court’s grant of summary judgment, vacating the judgment entered, and remanding the case for further proceedings.