Clifford's Notes

For years, Illinois courts have protected landowners from obvious dangers and risks on their property if it involved fire, drowning and falling from a height. These three dangers were considered examples of a per se obvious danger. Mt. Zion State Bank & Trust v. Consolidated Communications, Inc., 169 Ill.2d 110, 118, 660 N.E.2d 863, 863 (1995). A new wrinkle has been added to the concept of open and obvious …