Scoggins v. Brown

Pope, Chief Judge.

Plaintiff, a five-year-old boy who was injured when he stepped on a nail in defendants’ yard, appeals from the trial court’s grant of summary judgment for defendants.

Defendants (Mr. and Mrs. Brown) and plaintiff’s parents (Mr. and Mrs. Scoggins) were good friends, and plaintiff’s family frequently visited defendants. When Mr. Brown was working on a project around the house, Mr. Scoggins often gave him a hand, and that was what he was doing on the afternoon of plaintiff’s accident: Mr. Scoggins was helping Mr. Brown work on his deck, while Mrs. Scoggins and Mrs. Brown were sitting in the yard with the Scoggins’ daughter, and plaintiff was playing in the yard. The men were using wood from a woodpile near the back of the yard. All the adults knew the wood in the pile had nails in it, and both Mr. Brown and Mr. Scoggins warned plaintiff not to go near the woodpile because of the nails. Nonetheless, plaintiff followed his father to the woodpile and stepped on a board with a nail sticking out of it. Although plaintiff has now fully recovered, his wound became infected and surgery was required, resulting in medical bills in excess of $20,000.

*6021. Plaintiff first argues that the trial court erred in concluding he was a licensee rather than an invitee as a matter of law, and we agree. There is some evidence tending to show the Scoggins were social guests, in which case they were licensees; but there was other evidence that Mr. Brown invited the Scoggins for the purpose of obtaining Mr. Scoggins’ help with the deck, in which case they might be invitees. See Phillips v. Lindsey, 184 Ga. App. 728 (362 SE2d 491) (1987). Accordingly, a genuine issue of fact existed regarding the Scoggins’ status, and summary judgment should not have been based on this ground.

2. Nonetheless, summary judgment was properly granted for defendants because regardless of the Scoggins’ status, defendants met their duty of care by warning their guests of the dangerous nails in the wood. Where parents are watching their child play on someone else’s land and the parents are aware of a dangerous condition, it is the parents’ duty, not that of the landowner, to ensure that the child avoids the danger. See Wren v. Harrison, 165 Ga. App. 847 (303 SE2d 67) (1983). In this case, all the adults had equal knowledge of the dangerous nails in the woodpile, and plaintiff was within an arm’s reach of his father and within eyesight of his mother when the accident occurred. Moreover, plaintiff himself was warned several times not to go near the woodpile. Under these circumstances, the trial court did not err in concluding that plaintiff’s injury was not proximately caused by any negligence on the part of defendants as a matter of law.

Judgment affirmed.

Birdsong, P. J., Beasley, P. J., Andrews, Johnson, Blackburn, Smith and Ruffin, JJ., concur. McMurray, P. J., dissents.