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In Owens v. Ganga Hospitality, LLC, the Alabama Supreme Court addressed a negligence claim brought by a blind plaintiff, Janene Owens (“Owens”), who tripped over a curb at a hotel owned by the defendant, Ganga Hospitality, LLC (“Ganga”). The Montgomery Circuit Court granted summary judgment in favor of Ganga on Owens’s initial claims of negligence and wantonness. On appeal, the Alabama Supreme Court only addressed Owens’s negligence claim, and affirmed the lower court’s grant of summary judgment concluding that “Ganga owed Owens no duty because [the curb] was open and obvious.” The court also rejected the argument that Ganga violated the Americans with Disabilities Act (“ADA”) finding “no relevant ADA standard [of care] or violation in the present case” that would help support a finding of negligence.


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