A child was injured on church property when he tripped on one of several bricks surrounding the base of a large tree. While it was dark outside, there was sufficient light from outdoor floodlights to permit the victim and other children to play football.
A Florida appeals court ruled in favor of the church, on the ground that "we do not think that a tree with a surrounding brick border constitutes a dangerous condition or concealed peril," and accordingly "there was no duty on the part of the church to warn or take other precautionary measures, such as installing better lighting." Grajeda v. Winter Springs Community Evangelical Congregational Church, 509 So.2d 384 (Fl. App. 1987).