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By now, most of us have seen a funny warning sign or two, either in person or perhaps as a meme on social media. While these warnings may give us a quick laugh, can they also be useful in shielding against liability for bodily injury claims? The Third District of the Illinois Appellate Court thinks so, as set forth in its recent decision in Smith v. The Purple Frog, Inc., 2019 IL App (3d) 180132.

In Smith, plaintiff sued a bar for negligence after backing into a heater located in the bar’s outdoor beer garden and sustaining injury. Plaintiff had gone out to the beer garden to smoke. The heater was ...