As Afaq says in his comment, a color fill can interfere with placing a Spot Dimension. The other thing that can interfere is Model Graphics Style: Wireframe. A Spot Dimension can't "see" a surface if you are using Wireframe. It won't mind having a color fill or using wireframe after you place the Spot Dimension but you won't be able to place one while either condition exists.
Any other possibilities I might not be able to place a spot elevation on stair landing when it is in a linked model?
I'd guess your landing is above the view range, annotation tools have to "see" what they are meant to identify. If it is above you'll need to apply a Plan Region or adjust the View Range "up" until the Spot Elevation tool can "see" it.
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