In September 2018, the appellate department successfully convinced the First District Appellate Court to affirm the trial court’s grant of summary judgment for a Cray Huber client.  In Sarna v. The Club, et al., the Court opined in a Rule 23 Order that where the plaintiff sustained injury due to standing in the path of an opening door, the defendant property owner did not owe a duty of reasonable care to the plaintiff because the risk of injury was open and obvious.   The Court further opined that once the plaintiff had exited the premises with notice that he would not be permitted to reenter, he was no longer a business invitee.