Theoharis Lekas v. Dezer Properties, LLC, Dezer Development, LLC, Dezer Hotel Corporation of America, and 18001 Holdings, LLC
The Third District held that a premises owner owes no duty to warn or protect a barefoot guest from a hot cement pool deck or hot beach sand under the Florida summer sun. Cement pool decks and sandy beaches are common features of Florida life and are not inherently dangerous, and any heat-related danger is so open and obvious that an invitee may reasonably be expected to discover and avoid it. The plaintiff's diabetic neuropathy, which prevented him from perceiving the heat, did not convert an ordinary and obvious condition into a dangerous one or create a special duty.
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