"Out-of-Possession Landlord” Not Obligated to Make Repairs, Maintain Premises

Facts: A restaurant tenant’s employee required surgery for a broken wrist that he suffered in a slip-and-fall accident on a spiral staircase, used to access the employee locker room. The employee claimed that the staircase was greasy, and that the steps were worn smooth. He sued the owner for his personal injuries, claiming that the owner was responsible for maintaining the staircase in a safe condition. The owner asked a trial court for a judgment in its favor without a trial.