James Crain, et.al v. Baptist Memorial Hospital
James Crain, an apprentice electrician, sustained severe burns while working on an electrical project for TAM Electric Company, an independent contractor, at Baptist Memorial Hospital. Crain filed a lawsuit against Baptist Memorial Hospital, alleging negligence under a theory of premises liability, claiming the hospital owed him a duty to warn of latent defects or dangerous conditions. The trial court granted summary judgment to Baptist, determining that the work was inherently dangerous and thus, the landowner (Baptist) did not owe a duty of care to the independent contractor's employee. The Court of Appeals affirmed the trial court's decision, emphasizing that the exception to the general duty of a landowner applies when an independent contractor is hired to perform inherently dangerous work, and working with electricity falls into this category.