Richard Loweke v. Ann Arbor Ceiling & Partition Co

Summary

The court held that a party's contractual obligations do not extinguish or limit independently existing common-law or statutory duties owed to noncontracting third parties. The proper inquiry is whether the defendant owed the plaintiff any legal duty apart from the contract, not whether the alleged hazard or conduct was contemplated by the contract. Because the lower courts applied an erroneous understanding of that inquiry, the court reversed and remanded for further proceedings.