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Case Law Update: Negligence in Premises Liability

Rogers v. Matanda, No. 3-07-0855 (7/16/09) found that the trial court properly granted summary judgment for pub where Plaintiff fell during his 21st birthday celebration. Plaintiff had consumed 18 mixed drinks, and did not remember exiting tavern or falling. Plaintiff, who was removed from pub by his friends who blocked his efforts to re-enter, then tried to re-enter tavern by walking around to rear of building where there was a drop in elevation of several feet. Plaintiff failed to establish cause of his fall, and thus failed to make prima facie case as to proximate cause. This Illinois case will have an effect on premises liability and slip and fall cases.