Bobby Martin v. WPP Properties, LLC, Jennifer M. Williams, William R. Pulley and Zachary D. Pulley
Bobby Martin, an independent contractor, sustained a fractured hip after tripping and falling down an external staircase while performing 'make ready' renovation work at the Manor Terrace Apartment complex, owned by WPP Properties, LLC. He subsequently sued WPP Properties, LLC, Jennifer M. Williams, William R. Pulley, and Zachary Pulley (Appellees) alleging negligence and premises liability. The trial court granted summary judgment for Appellees, concluding that Chapter 95 of the Texas Civil Practice and Remedies Code applied and that Appellees did not retain control over Martin's work. The appellate court affirmed, holding that Martin's work constituted 'renovation' under Chapter 95, the staircase was part of the same 'improvement' as the apartment, and Martin failed to establish a fact issue regarding Appellees' control over his work, which is a prerequisite for liability under Chapter 95.