Free: An Insider’s Advice for
Maximizing Slip and Fall Settlements


Slip and fall cases can be difficult to win.  Failure to prove a causative link between the hazard and a negligent act of the defendant is the number one reason for the high number of losses in slip and fall cases.

In these free chapters, Charles Turnbow, attorney-engineering consultant on over 9,000 slip and fall cases, provides you with an organization system and the tools to efficiently develop persuasive slip and fall claims. He shows you how to prove the causation (and how to efficiently screen out cases lacking it) by:

  • Analyzing the mechanics of the fall to identify the cause

  • Making sure your case has the attributes necessary to win

  • Documenting the dangerous condition and the negligence that caused it

  • Establishing the duty of care

  • Proving control of the premises

  • Establishing actual or constructive notice

  • Showing that the hazard caused the injury

 

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Case Evaluation

Chapter 1.       In the Beginning

Chapter 2.       Premises Liability Law

Chapter 3.       Building Codes

Chapter 4.       Mechanics of Walking

Chapter 5.       Measurements and Testing

Chapter 6.       Case Evaluation

 

Litigation

Chapter 7.       Pleadings

Chapter 8.       Depositions

Chapter 9.       Production of Documents, Interrogatories and Inspection Demands

Chapter 10.     Selection and Use of Expert Witnesses

Chapter 11.     Determining Damages

Chapter 12.     Defending a Slip and Fall Case

Chapter 13.     Settlement and Arbitration

Chapter 14.     Preparing Documents and Evidence for Trial

Chapter 15.     The Trial

 

Categories of Cases

Chapter 16.     Workplace Falls

Chapter 17.     Falls on Public Property

Chapter 18.     Falls in Markets

Chapter 19.     Falls in Residences

Chapter 20.     Falls on Construction Sites

Chapter 21.     Falls at Recreational Facilities

Chapter 22.     Falls on Ice and Snow

Chapter 23.     Falls by the Elderly or Disabled

Chapter 24.     Playground Accidents



 


   Here are the first 7 pages of a 27-page chapter:

Chapter 18

Falls in Markets

§1800      Introduction

§1801      Basis of Law

§1802      Critical Elements

§1803      Three Basic Items

§1804      Application of Premises Liability Law

§1805      Burden of Proof

§1810      Proving the Elements

Case 1:    Defendant Store Has Duty to Inspect

§1811      The Wollerman Rule

§1820      Source of Hazard

Case 1:    Absence of Hazard

Case 2:    Mysterious Causes

§1830      Business Owner’s Duty

Case 1:    Failure to Warn

Case 2:    Failure to Inspect

Picture:    Cluttered Aisles

§1840      Establishing Notice

Case 1:    Sweeping Logs

§1840.1  New Technologies

Case 2:    Special Maintenance Problems – 24-Hour Market

Case 3:    Gratuitous Use of Premises

Case 4:    Failure to Inspect

§1841      Mode of Operation

§1842      Merchandise and Other Distractions

Case 1:  Distracting Display

Picture:  Riser and Warning Sign

§1850      Questions and Answers

Figure 18-1:         Typical Grocery Store Sweep Log

§1851      Employee Training

Case 1:  Employee Training

§1852      Distractions

Case 1:  Distractions in the Store

§1860      Demonstrative Evidence

§1861      Photographs

§1862      Video

§1870      Supermarket and Retail Store Checklist

§1880      Additional Sources

§1881      Sample Complaint for Fall in Supermarket

§1882      Demand for Production of Documents

§1883      Demand for Inspection of Property

 

 

§1800  Introduction

Falls in retail stores and other businesses are not the most common slip and fall accidents, but they are probably the most litigated. The relationship between the business owner and the patron has created a special duty to provide premises that are reasonably safe. Even where there is no distinction between invitees and licensees, special duties are charged to the business owner.

The duty may be based on traditional common law or on the newer concept of the so-called “mode of operation” theory of liability. The manner in which the merchandise is packaged or displayed may impose additional duties on the business owner. In Bloom v. Fry’s Food Stores, 130 Ariz. 447 (Ariz. Ct. App. 1981), the court held that the plaintiff may be relieved of the burden of proving notice where the occurrence of a transitory hazardous condition may be reasonably anticipated. See also Chiara v. Fry’s Food Stores, 733 P.2d 283 (Ariz. 1987); Lopez v. Superior Court, 45 Cal. App. 4th 705 (Cal. App. 2d Dist. 1996). Bloom involved a patron of the grocery store falling after stepping on grapes. The grapes were displayed loose in bins. There was no evidence that could be used to determine how long the grapes had been on the floor. The rationale of the court was that sooner or later grapes would be likely to fall to the floor when they were displayed in this manner, and therefore the store had a duty to anticipate this occurrence. “[I]n a self-service market operation, the storekeeper must take reasonable protective measures for the benefit of customers who might slip and fall on vegetable material dropped on the floor by others.” (Lopez v. Superior Court, 45 Cal. App. 4th 705, 716 (Cal. App. 2d Dist. 1996).)

After considering a similar case six years later, the court coined the phrase “Mode of Operation” was coined to describe the application of a relatively new rule that extended of the theory of liability where the storekeeper would be negligent if he failed to inspect or clean his store. Under this extension, the plaintiff could establish liability “by showing that the operator of the premises had failed to conduct periodic inspections and the frequency required by the foreseeability of risk.” However, “[t]he plaintiff must still prove that defendant failed to take reasonable care to prevent injury.” Chiara v. Fry’s Food Stores, 733 P.2d 283, 285 (Ariz. 1987); Brooks v. Phillip Watts Enterprises, Inc., 560 So. 2d 339, 341 (Fla. Dist. Ct. App. 1st Dist. 1990); Jackson v. K-Mart Corp., 828 P.2d 941, 947 (1992), aff’d 840 P.2d 463 (1992); Pimentel v. Roundup Co., 666 P.2d 888, 893 (1983); Ortega v. Kmart Corp., 26 Cal. 4th 1200, 36 P.3d 11 (2001). These cases shift the burden to the defendant to prove that he took adequate precautions to make his store safe by regular and frequent sweeping or inspections. In Lopez v. Superior Court, 45 Cal. App. 4th 705 (Cal. App. 2d Dist. 1996), the court found that reasonable care to prevent injury could include the addition or alteration of floor surfaces which would not present a slipping hazard when wet or contaminated.

Thus the manner of operation and the type of articles on display are more important than the length of time the object had been on the floor. Where the hazardous condition is the results of a failure to reasonably maintain the premises, this failure may be the basis for negligence and actual or constructive notice is not necessarily required. The plaintiff may be excused from proving notice where the existence of the hazard is reasonably foreseeable. See Morton v. Lee, 75 Wn.2d 393 (1969); Pimentel v. Roundup Co., 100 Wn.2d 39, 666 P.2d 888 (1983); Sheil v. T.G. & Y. Stores Co., 781 S.W.2d 778 (Mo. 1989); Jackson v. K-Mart Corp. 840 P.2d 463, 469 (1992); Gump v. Wal-Mart Stores, Inc., 5 P.3d 407, 411 (Hawaii 2000).

“If the store owner’s practices create a higher risk that dangerous conditions will exist, ordinary care will require a corresponding increase in precautions.” Moore v. Wal-Mart Stores, Inc., 111 Cal. App. 4th 472 (Cal. App. 5th Dist. 2003.) (For an additional discussion of mode of operation, see §233.1, supra.)

§1801  Basis of Law

Plaintiffs used to be faced with a frightful burden of proving both breach of duty and notice. Over time, the courts eased plaintiffs’ burden. For example, in 1954 a California court in Hale v. Safeway Stores, Inc., 129 Cal. App. 2d 124 (Cal. App. 1954) held that frequent inspection of the sales areas in markets was necessary and that 12-15 minutes between inspections would not be unreasonable.

Other states adopted a similar rule, holding that the foreseeability of the circumstances would create a condition that could pose a danger to the patrons. As a result of the number of lawsuits and as a means of providing a reasonably safe shopping environment, supermarket and grocery chains developed safety procedures through which the hazards could more quickly be identified and abated. Chiara v. Fry’s Food Stores, 733 P.2d 283, 285 (Ariz. 1987); Brooks v. Phillip Watts Enterprises, Inc., 560 So. 2d 339, 341 (Fla. Dist. Ct. App. 1990); Jackson v. K-Mart Corp., 828 P.2d 941, 947 (1992), aff’d 840 P.2d 463 (1992); Pimentel v. Roundup Co., 666 P.2d 888, 893 (1983); Ortega v. Kmart Corp., 26 Cal. 4th 1200, 36 P.3d 11 (2001).

§1802  Critical Elements

Obviously, there must be some type of hazard if a negligence action is to succeed. Wet or contaminated floors are the most common cause of supermarket slip and fall accidents. Merchandise or debris on the floor is often alleged to be the accident cause. Structural failures and defects in the walkway surface come in at a distant third.

Most often the hazards are self-documenting and do not require expert testimony to establish the existence of a hazard. For example, spilled cooking oil on a smooth floor creates an undeniably slippery surface. Vegetable matter, liquids and other debris fall into the same general category. While testing of the floor surface is helpful, its importance is secondary to establishing notice.

Notice is the main issue in nearly every retail store slip and fall case. Since actual notice is rarely supported by the facts of the case, constructive notice must be established by the plaintiff. This is most often done through expert testimony. If the plaintiff cannot prove actual, constructive or implied notice, or cannot show that the defendant did not safely maintain his premises through frequent, regular and competent inspections or cleaning, then there is little hope for success.

§1803  Three Basic Items

All fall accidents in retail stores include the same three ingredients: the shoes, floor, and pedestrian. The plaintiff must be able to narrow the issues or causes of the incident. Expert testimony is most often used to eliminate one or more of these elements as a substantial contributing factor to the cause of the accident.

Shoes. Where possible, the expert can examine, inspect or test the shoes worn by the plaintiff so that they may be eliminated as a cause, or in the alternative, to develop sufficient evidence that can serve as the basis of a products liability action against the shoe retailer or manufacturer. Some sole and heel materials are inherently slippery, and therefore defective, regardless of the floor surface. Every slip and fall case should be evaluated as a potential products liability case. Most shoes are not defective so the physical characteristics of the shoes should be carefully evaluated so they can be ruled out as a contributing factor to the cause of the accident.

Floor. Lack of adequate traction is the most common cause of falls in retail stores. A contaminated or wet surface substantially reduces the amount of available traction and creates a slippery condition. Measurement and testing of the floor is covered in detail in Chapter 4. There usually has to be some showing that the floor was dangerous under the conditions existing at the time of the accident.

Pedestrian. In most market slip and fall cases, the plaintiff falls victim to a hazard while shopping or doing other things that are both reasonable and foreseeable. On occasion, however, some or most of the fault lies with the pedestrian. A reasonable and sometimes effective defense is that the patron acted in an imprudent or unreasonable manner, such as running within the store, climbing over displays or merchandise or failure to heed signs or warning devices. Similar to the burden placed on the business owner to prove that he acted reasonably in the maintenance and safety of the store, the plaintiff should show that her activities were not only reasonable but foreseeable under the circumstances.

§1804  Application of Premises Liability Law

The market has a duty to maintain its premises in such a manner that it does not create an unreasonable risk of harm to the patrons. It must exercise ordinary care under the circumstances to minimize the commonly occurring slipping hazards. Industry standards create the bar by which the activities of the defendant are measured. The retail store industry has adopted inspection and maintenance procedures, which are designed to minimize these hazards.

Under modern case law, if the defendant does not conduct regular and frequent inspections of his premises, the courts will permit the assumption that the hazard was in place a sufficient length of time for the defendant to have reasonably corrected or abated it. Bridgman v. Safeway Stores, Inc., 348 P.2d 696 (1960); Sapp v. W. T. Grant Co., 341 P.2d 826 (Cal. App. 1959); Bloom v. Fry’s Food Stores, 636 P.2d 1229 (Ariz. App. 1981); Bozza v. Vornado, Inc., 200 A.2d 777 (1964); Mahoney v. J. C. Penney Co., 337 P.2d 663 (N.M. 1962); Presnell v. Safeway Stores, Inc., 374 P.2d 939 (1962); Chiara v. Fry’s Food Stores, 733 P.2d 283, 285 (Ariz. 1987); Brooks v. Phillip Watts Enterprises, Inc., 560 So. 2d 339, 341 (Fla. Dist. Ct. App. 1990); Jackson v. K-Mart Corp., 828 P.2d 941, 947 (1992), aff’d 840 P.2d 463 (1992); Pimentel v. Roundup Co., 666 P.2d 888, 893 (1983); Ortega v. Kmart Corp., 26 Cal. 4th 1200, 36 P.3d 11 (2001).

§1805  Burden of Proof

The plaintiff must show that the hazard was the result of the activities of the defendant or the failure to act was the result of the defendant’s breach of his duty to reasonably maintain the premises in a safe manner. This proof usually requires an expert to establish the custom and practice of the industry, to document the existence of the hazard and to establish reasonable and necessary safety procedures for inspection and maintenance of the premises.

Under some circumstances, the burden of proof shifts to the defendant. For example, most modern courts require the defendant market to prove that he exercised reasonable care in the maintenance of his premises. The defendant now has to present evidence that inspections and cleaning were done on a frequent and adequate basis, that the defective condition of the floor did not result from any negligent act of the defendant or his employees and that he did not have actual or constructive notice of the hazard. See Chiara v. Fry’s Food Stores, 733 P.2d 283 (Ariz. 1987); Brooks v. Phillip Watts Enterprises, Inc., 560 So. 2d 339 (Fla. Dist. Ct. App. 1990); Jackson v. K-Mart Corp., 828 P.2d 941 (1992); Pimentel v. Roundup Co., 666 P.2d 888 (1983); Ortega v. Kmart Corp., 26 Cal. 4th 1200, 36 P.3d 11 (2001).

§1810  Proving the Elements

Notice is the most critical element that needs to be established. Without notice evidence, there is little hope of success. The existence of the hazard is next in importance. For example, an expert may be needed to establish that under normal use conditions the floor surface is slippery and that special precautions would be necessary to render the floor reasonably safe.

Case 1: Defendant Store Has Duty to Inspect

A male patron was shopping at a general merchandise discount store when he slipped in a puddle of milk on the floor adjacent to a refrigerator and suffered significant injuries to his knee, including ligament tears. Less than a year later, the plaintiff sued the store for personal injuries. At trial, the plaintiff testified that he did not notice whether the puddle of milk was fresh or odorous, warm or cold. He could not present evidence showing how long the milk had been on the floor. Nonetheless, the plaintiff claimed that because the evidence showed the retailer had not inspected the premises in a reasonable period of time prior to the accident, a jury could infer the puddle was on the floor long enough for the store employees to have discovered it.

Plaintiff’s maintenance expert conceded that he found no direct evidence indicating how long the puddle had been on the floor before the plaintiff’s fall. He did opine that this store and similar ones should implement three basis management tools relevant to floor maintenance: (1) accountability (the name of the person who performs the inspections should be identified); (2) frequency (management should know how often the floor is inspected); and (3) verification (a written record or some other form of verification should be presented to management).

A former store manager testified that although the store keeps no written inspection records, all store employees are trained to look for and clean up any spills or other hazards. He also stated that several employees work in the pantry aisles next to the milk refrigerator, and that an employee usually walked the aisle where the plaintiff slipped every 15 to 30 minutes. When asked whether milk could have been on the floor for five minutes or two hours, the manager testified that it would be hard for anything to be on the floor for more than 15 to 30 minutes. He did admit, however, that the milk could have been on the floor for as long as two hours. On the day of the accident, the manager testified that management would not have any idea if the aisle where the accident occurred was inspected at any time during that day. The store claimed that the plaintiff failed to carry his burden of showing the milk puddle existed for a sufficient time to establish constructive notice to the store.

The trial jury found for the plaintiff and the verdict was appealed. The California Supreme Court found that the plaintiff could be relieved of his burden of showing how long the milk remained on the floor if he demonstrated the site had not been inspected within a reasonable period of time. Ortega v. Kmart Corp., 26 Cal. 4th 1200, 36 P. 3d 11 (2001).

“Circumstantial evidence of a property owner’s failure to inspect the premises before an accident is sufficient to infer the risk existed long enough for the property owner, in the exercise of due care, to have discovered and removed it. In other words, a property owner’s failure to reasonably inspect can be used to infer constructive knowledge of the dangerous condition, providing a causal link between the accident and the time period between inspections. The determination of what constitutes a reasonable time period between inspections will necessarily vary according to the particular circumstances. For instance, “‘[A] person operating a grocery and vegetable store in the exercise of ordinary care must exercise a more vigilant outlook than the operator of some other types of business where the danger of things falling to the floor is not so obvious.’ [Citation].” Thus, while a 15- to 30-minute interval between inspections at a busy commercial retail center may lead to an inference of negligence, the same inference might not be found elsewhere.” Ortega v. Kmart Corp., 26 Cal.4th 1200, 1210 (2001).

Duty to inspect is also reflected in the following cases: Keller v. Schwegmann Bros., Inc., 402 So. 2d 724 (La. App. 1981); Gonzales v. Winn-Dixie La., 326 So. 2d 486 (La. 1976); Hale v. Safeway Stores, Inc., 129 Cal. App. 2d 124 (Cal. App. 1954); Bridgman v. Safeway Stores, Inc., 348 P.2d 696 (1960); Thompson v. Economy Super Marts, 221 Ill. App. 3d 263 (Ill. App. 1991); J. C. Penney Co. v. Barrientez, 411 P.2d 841 (Okla. 1965); Bozza v. Vornado, Inc., 42 N.J.355 (1964); see also 24 A.L.R. 4th 696, Liability of Operator of Grocery Store to Invitee Slipping on Spilled Liquid or Semiliquid Substance.

§1811  The Wollerman Rule

To create a more equitable balance in regard to the burden of proof in supermarket slip and fall cases, the court in Wollerman shifted the burden of proof to the defendant, Grand Union, to show that it exercised reasonable care in maintaining its stores. Wollerman v. Grand Union Stores, Inc., 221 A.2d 513 (1966). See also Bozza v. Voonado, Inc., 200 A.2d 777 (1964).

While the Wollerman ruling created only a permissible inference of negligence, it has been the basis of subsequent holdings that the defendant must show a lack of negligence by proving he acted in a reasonable and prudent manner rather than the plaintiff having to establish both notice and breach. This ruling and others like it has protected the plaintiff from summary judgment when it has been established that (a) a transitory hazard on the defendant’s premises caused the plaintiff to injure herself and (b) patrons were likely to create transitory hazards under the normal operation of the business. The court ruled that “it was fair to place the onus of producing evidence” on the defendant that he had taken reasonable steps to protect the plaintiff from a risk of harm inherent in the store’s self-service method of operation.

The Wollerman Rule can be simply stated as: “[W]here a substantial risk of injury is implicit in the manner in which a business is conducted, and on the total scene it is fairly probable that the operator is responsible either in creating the hazard or permitting it to arise or to continue, it would be unjust to saddle the plaintiff with the burden of isolating the precise failure.” See Chiara v. Fry’s Food Stores, 733 P.2d 283, 285 (Ariz. 1987); Smith v. Safeway Stores, Inc., 636 P.2d 1310 (Colo. App. 1981); Forcier v. Grand Union Stores, 264 A.2d 796, 800 (1970).

§1820  Source of Hazard

Occasionally, a slip and fall accident will occur when the floor is clean and dry. Victims of such falls usually allege that the floor was dangerous because it was highly polished and shiny. Modern commercial waxes have high coefficients of friction when properly applied to the floor, leaving little danger of slipping. 

Case 1: Absence of Hazard

The plaintiff and a friend were shopping in a large supermarket. The plaintiff slipped and fell while walking toward a store display. Prior to the fall, the plaintiff did not see any foreign material on the floor and did not think the floor was slippery. After the fall, however, he did notice that the floor was very shiny and appeared to be highly polished. No witnesses could confirm the floor’s condition or the presence of any foreign material. While this market did not maintain sweep sheets, competent testimony indicated that the floor had been swept and inspected within the hour.

The plaintiff filed an action based on negligent maintenance of the floor. To establish the hazard, the plaintiff relied on her observation that the floor was very shiny and appeared to be highly polished. After answering the complaint and conducting rather extensive discovery, the defendant filed a motion for summary judgment.

After a trial court ruling, the California Court of Appeal affirmed that the motion for summary judgment should have been granted based on the plaintiff’s failure to establish a hazard. There was no offer of evidence that the floor was actually slippery. In depositions, the eyewitness and store employees all testified that the floor did not seem slippery and that they had no difficulty in negotiating the surface. The court held that the mere fact that the floor appeared to be highly polished and shiny was not sufficient proof that it was slippery. If the condition could not be seen, recognized or measured, the defendant would have no opportunity to take any remedial measures to abate the hazard. Buehler v. Alpha Beta Co., 224 Cal. App. 3d 729 (Cal. App. 1990).

Case 2: Mysterious Causes

The plaintiff was walking down the household products aisle of a discount department store when she slipped and fell, causing serious injury. The plaintiff said the floor was extremely slippery, causing her right foot to slide forward.

Paramedics stated that the floor seemed slippery as they treated the plaintiff. Store management denied that there was any liquid or debris on the floor. The plaintiff did not see anything on the floor. According to testimony and written records, the floor was routinely stripped, waxed and buffed using a commercial floor treatment compound that provided a nonslip finish.

The plaintiff retained a safety expert to evaluate the floor and to determine whether the store followed custom and practice in the inspection and maintenance of the area. Coef­ficient of friction measurements produced values that suggested the floor was not slippery (above 0.50). At the time of the expert’s inspection, there was no condition that could have caused the plaintiff to slip.

Careful examination of the merchandise on the household products aisle revealed that the majority of products were aerosol spray cans of furniture polish and dusting compounds. During business hours, patrons sprayed the products to smell them. The fine mist of the furniture spray settled on the floor. When the expert measured the coefficient of friction on that particular portion of the floor, she found it to be very slippery, with coefficients of friction of about 0.18. Because routine sweeping and inspection of the floor would have likely removed the overspray, the jury found that the store was negligent in its lack of daytime sweeping.

There was never any evidence of overspray on the day of the plaintiff’s fall. However, something caused the floor to be observably slippery, and test spraying of aerosol cans is rather common. Both the hazard and resulting accident were foreseeable. As a precaution, the store should have swept the area on a regular basis.

In each of the above cases, there was no observable material on the floor. In the first case, the plaintiff failed to establish a defect or hazard for which the defendant was responsible. In the latter case, the plaintiff prevailed because she and others testified to the hazard, and the store did not take reasonable precautions to correct the foreseeable hazard.

Often there is conflicting testimony as to the existence of liquid on the floor. Testing is likely to prove that the floor is safe in the absence of liquid. If there is conflicting testimony, it may be sufficient to show that the accident could not have happened unless a lubricant was on the floor.

Many markets fill out incident reports and take photographs soon after the accident. The reports are sent to the risk management department to use in potential litigation. In states where such reports and photographs are not considered work product, demand production during the discovery process. Stores frequently document the hazard in these reports.

§1830  Business Owner’s Duty

If the defendant knows or should have known of a condition that foreseeably could present a danger to the patron, he or she has a duty to use ordinary care in removing the hazard or adequately warning the patron of its existence. The customer has a right to assume that the business premises are reasonably safe unless there are indications or warnings to the contrary. See Whittaker v. Schwegmann Bros. Giant Supermarkets, 334 So. 2d 756, 757 (La.App. 4 Cir. 1976). See also Bruce J. Oreck, The Game’s Afoot: the Storekeeper’s Heightened Responsibility for Slip and Fall Accidents, 37 La. L. Rev. 634, 639 (1977).

Case 1: Failure to Warn

As the plaintiff entered a fast food restaurant in a shopping mall, she noticed a restaurant employee mopping part of the floor. She also observed at least one sign that read: “Caution, Wet Floor.”

After eating, the plaintiff slipped and fell while leaving the restaurant. She did not see any water or liquid on the floor where she slipped but noticed that her clothes were wet. After the fall, the plaintiff saw the warning sign, but not the employee mopping the floor. The restaurant manager testified that the fall occurred in a location that was outside the perimeter delineated by the signs.

The plaintiff’s expert testified that the wet floor was slippery and dangerous. The slipperiness was increased due to an improper method of rinsing and drying the floor.

After a jury trial, judgment was entered for the defendant. The plaintiff appealed based on the court's failure to instruct the jury on the proprietor's duty to remedy or warn of the hazard. The Court of Appeal agreed with the plaintiff's position and held that the defendant has a duty to use effective warning devices.

The above case, Williams v. Carl Karcher Enterprises, Inc., 182 Cal. App. 3d 479 (Cal. App. 1986), formed the basis of a modification in the California’s standard jury instruction BAJI 8.01, which now reads, “The owner of premises is under a duty to exercise ordinary care in the use, maintenance or management of such premises in order to avoid exposing persons to an unreasonable risk of harm. Such duty exists whether the risk of harm is caused by the natural condition of such premises or by an artificial condition created on such premises.” The Williams court reasoned that ordinary care would include both maintenance and inspection for defects. This duty to inspect and correct was affirmed by the California Supreme Court in Ortega v. Kmart Corp., supra. A store owner exercises ordinary care by making reasonable inspections of the portions of the premises open to customers, and the care required is commensurate with the risks involved (Ortega, supra, at p 1206). Since the risk of slipping is greater in areas of the store where produce, liquids or solid material spills are more common, these areas require more frequent inspections. While hourly inspections may be reasonable for other portions of the store, the high risk areas may require inspections as frequent as every 12 to 15 minutes (Hale v. Safeway Stores, 129 Cal. App. 2d 124, 276 P 2d 118 (1954).

The defendant has a duty to keep the premises reasonably safe and to inspect for defects and potential hazards. While the storekeeper is not the insurer of customers’ safety, he or she owes an affirmative duty to exercise reasonable care to keep the aisles, passageways and floors in a safe condition. The storekeeper also has a twofold duty to discover and correct reasonably anticipated dangerous conditions.

After Ortega, the issue of establishing notice of a dangerous condition was again addressed by the appellate court. Using a standard jury instruction as a guide, the court quotes BAJI No. 8.24, which provides in part:

“... A store owner is not negligent unless [he] actually knew or reasonably should have known of the dangerous or defective condition a sufficient time before the accident to have either remedied the condition or provided warning or protection against it. An owner reasonably should know of a dangerous or defective condition if it existed for a sufficient length of time before the accident that if the owner had exercised reasonable care in inspecting the premises, the owner would have discovered the condition in time to remedy it or to give warning or protection before the injury occurred. ...”

The revised civil jury instructions, California Approved Civil Instruction 1011, restate this principle as follows:

“In determining whether [name of defendant] knew or should have known of the condition that created the risk of harm you must decide whether, under all the circumstances, the condition was of such a nature and existed long enough so that it would have been discovered and corrected by an owner using reasonable care.

“If an inspection was not made within a reasonable time before the accident, this may show that the condition existed long enough so that a storeowner using reasonable care would have discovered it.” (Jud. Council of Cal. Civ. Jury Instns. (July 16, 2003, approved draft) No. 1011). Moore v. Wal-Mart Stores, Inc., 111 Cal. App. 4th 472 (Cal. App. 5th Dist. 2003), Ortega v. Kmart Corp., (2001) 26 Cal.4th 1200, 1210-1211.

The Moore Court presents the opinions of sister state courts, which appear to permit the finding of negligence without proof of notice.

“The ‘mode-of-operation’ rule looks to a business’s choice of a particular mode of operation and not events surrounding the plaintiff’s accident. Under the rule, the plaintiff is not required to prove notice if the proprietor could reasonably anticipate that hazardous conditions would regularly arise. [Citations omitted.] In other words, a third person’s independent negligence is no longer the source of liability, and the plaintiff is freed from the burden of discovering and proving a third person’s actions...” Jackson v. K-Mart Corp., 840 P.2d 463, 469 (1992); Gump v. Wal-Mart Stores, Inc., 5 P.3d 407, 411 (Hawaii 2000).

Case 2: Failure to Inspect

While shopping in the clothing department of a discount store, the plaintiff caught her foot on a white plastic clothes hanger that had fallen onto a light colored floor. The defendant testified that there were no regular sweeping or inspection schedules in force at that time. The company policy charged each employee with the responsibility of continually inspecting the sales area and to promptly pick up any material that might present a hazard.

The defendant store appealed the trial court’s award to the plaintiff. The Louisiana Court of Appeal held that the store had a twofold duty to inspect and correct dangerous conditions that might present hazards to patrons. The trial and appellate courts found that the store’s failure to conduct regular inspections of the sales floor did not meet this level of care. See Deville v. K-Mart Corp., 498 So. 2d 1122 (La.App. 3 Cir. 1986).

The duty of the business owner is the basis of good risk-management practices. Where businesses have instituted safety programs, the emphasis for public safety is on inspection and maintenance or repair. The inspection aspect of this duty is important in the issue of notice.

Deville is based, in part, on earlier cases that established the so-called “Louisiana Rule” which shifts the burden of proof to the defendant requiring him to prove that his practices of inspection and maintenance are reasonable and adequate. See Kavlich v. Kramer, 315 So. 2d 282 (La. 1975); Gonzales v. Winn-Dixie La., 326 So. 2d 486 (La. 1976); Brown v. Winn-Dixie La., 452 So. 2d 685 (La. 1984); McCardie v. Wal-Mart Stores, 511 So. 2d 1134 (La. 1987).

§1840  Establishing Notice

Case law has clearly established the business owner’s duty to inspect and maintain the premises in a safe manner and to correct any defects found during an inspection. To be effective, the inspections must be frequent enough to reasonably identify hazards so that corrective action can be promptly taken.

Hourly sweeping and intermediate inspections of the sales area are generally recognized as adequate to maintain a reasonably safe floor. Most accidents occur when this inspection system breaks down. The sweeping records, sheets or logs are the only practical means of determining that inspections have occurred according to the company’s safety policy. These logs become very effective in establishing constructive notice.

Case 1: Sweeping Logs

A supermarket chain implemented a safety program that substantially reduced the number of customer injury claims. The program consisted of hourly sweeping of the entire store, half-hourly sweeping of the lobby and produce department, twice hourly inspection by key-carrying management personnel, and the use of safety mats in critical areas of the produce department and near the entry doors. Each sweeping was logged onto sweep sheets using an electronic time clock. The sweep sheets were reviewed by the store manager and risk management personnel. This inspection and sweeping procedure proved to be effective in reducing accidents and supplied a good defense to the relatively few claims that were litigated.

In this case, the plaintiff was walking past an instant drink display when she slipped on a film of powdery mix that had leaked from one of the packages. The powder, visible on inspection but somewhat difficult to see on casual observation... (continued in full chapter)

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