Michigan Condo Liability to Short-Term Guests (Letvin)

Quick Answer

On July 13, 2026, the Michigan Court of Appeals issued a published opinion in Letvin v. Village at Grand Traverse Commons Condominium Association, Docket No. 376558. The court held, as a matter of first impression, that a short-term rental guest of a condominium unit owner is an invitee of the association while on the common elements the association maintains. Invitees are owed the highest duty of care in Michigan premises liability law. For boards, that means ice, snow, lighting and other common-area conditions must be handled as if every guest, not just every owner, relies on your maintenance.

What Happened

The plaintiff stayed in a unit booked through Airbnb in January 2023. He fell on ice in a parking lot of the condominium development and broke his arm. The association had hired a contractor to remove snow and salt, but the board president testified that the board took no responsibility for monitoring the contractor's work, and the contractor's owner was not aware of anyone from the association inspecting it. The trial court treated the plaintiff as a licensee, which carries a much lower duty, and granted summary disposition to the association.

What the Court Held

• Invitee, not licensee. The court held that the guest is an invitee of the association on the common elements it maintains. It reasoned that part of the assessments owners pay funds safe common areas for owners and their guests, so the association receives an indirect economic benefit from guests, as a landlord does from a tenant's right to invite others.
• Janini drives the reasoning. The court relied on the Michigan Supreme Court's 2024 decision in Janini v London Townhouses Condominium Association, 514 Mich 86, which held that co-owners using common areas the association maintains are invitees and compared the association-owner relationship to landlord and tenant.
• An earlier case no longer controls here. The court concluded that Janini abrogated Gabrielson v Woods Condominium Association, 349 Mich App 478 (2024), as applied to renters injured in common areas the association maintains, and followed the older Stanley v Town Square Cooperative, 203 Mich App 143 (1993).
• Breach is a jury question here. The court reversed summary disposition because the evidence raised factual questions about whether the association took reasonable measures within a reasonable time to reduce the ice hazard, including whether it adequately oversaw its contractor.

What the Court Did Not Decide

The court did not hold the association was negligent. It sent the case back for further proceedings. The opinion is published, but it remains subject to revision until final publication and could be reviewed further, so boards should watch for later developments. It addresses short-term rental guests; the reasoning may also reach other renters and, depending on the facts, other visitors, but that is not yet settled.

Why Snow and Ice Management Is the Real Lesson

Michigan law, as the opinion notes, requires a landowner to take reasonable care to protect invitees from the natural accumulation of ice and snow. Hiring a contractor does not by itself end the inquiry. The record in Letvin turned in part on the absence of any association oversight. Photographs, testimony and inspection records were what the court looked to.

Board and Manager Action Checklist

• Write down who inspects. Assign a named person to inspect parking lots and walkways during and after winter storms, and keep dated logs and photos.
• Tighten the snow contract. Define triggers, response times, re-salting and re-inspection duties, and require the contractor to carry liability insurance naming the association as additional insured with indemnification. See our Michigan vendor management guide.
• Log complaints and fixes. Record every hazard report and the response time.
• Call your insurance agent. Confirm general liability limits and ask how short-term rental guests and contractor claims are handled.
• Revisit your rental policy. If your documents permit short-term rentals, review whether limits, registration or guest-information rules make sense. Our guide to short-term rentals in Michigan associations covers the options, and our guide to board member liability and D&O insurance explains related exposure.
• Do not assume the unit owner carries the risk. A rental owner's policy does not remove the association's own duty for common areas.

How APM Helps

APM manages vendor contracts, inspection schedules and incident documentation for Michigan associations. See our Michigan resources or contact us to review your winter maintenance plan before the first storm.

Source: Letvin v The Village at Grand Traverse Commons Condominium Association, Mich Ct App No. 376558 (July 13, 2026) (published). This article summarizes the opinion for general information and is not legal advice; subsequent history may change its effect. Consult your association's attorney about your specific facts. Last verified October 24, 2026.