Eric J. v. BETTY M.

When Robert was released from prison on rehabilitative parole after having been convicted of felony child molestation four years earlier, his family might have disowned him, but they didn’t. They accepted him back. And when he found a girlfriend named Helen—who had an eight-year-old boy named Eric—they did not tell Helen about Robert’s previous conviction, no doubt hoping against hope that he had reformed himself.

Unfortunately, and unbeknownst to any members of the family or Helen herself, Robert began molesting Helen’s son early on in his relationship with her. Helen, acting as Eric’s guardian, has now sued various members of Robert’s family for not telling her of his previous conviction. Because some of the sexual abuse occurred on property owned by family members, Helen has asserted premises liability as well as general negligence as her two theories of liability.

The trial judge granted the family members’ motion for nonsuit, and we now affirm the ensuing judgment. As we explain below, under the circumstances of this case, premises liability is a make-weight because there was no relationship between the harm and any premises owned by family members on which the…