In a premises liability lawsuit, the plaintiff alleged that the landowner owed him a duty of care under the applicable municipal ordinance and/or under the common law to maintain and cut the grass of the adjacent parkway abutting the defendant’s property. The plaintiff, a tenant of the adjacent property, was walking from his car to the apartment at night when he tripped on a raised water valve that was allegedly obscured by 10” of tall grass in a small parkway adjacent to the property owned by the State Bank of Geneva, as Trustee under Trust #1010. A Geneva ordinance required the adjacent property owner to trim the parkway grass to ensure that it did not exceed 8” tall. State Bank of Geneva argued that it did not owe a duty of care to the plaintiff under the ordinance since the ordinance was not a public safety measure nor did it create a private right of action. Further, the State Bank of Geneva argued that it owed no duty under the common law since it did not appropriate the property for its own use, it did not actively create the alleged hazard by its conduct and the parkway in question was not the sole means of ingress and egress to the adjacent apartment. The Appellate Court agreed and found there was no issue of fact and affirmed summary judgment. Ingold v. The City of Geneva, 2023 ILL App (2d) 220413-U (2023).