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Reviewing Brief

Opposing counsel filed this summary judgment brief arguing our client’s slip-and-fall claim should be dismissed for lack of notice. Review it and identify the best counter-arguments.
Opposing counsel filed this summary judgment brief arguing our client's slip-and-fall claim should be dismissed for lack of notice. Review it and identify the best counter-arguments.
Read opposing_counsel_msj_brief.pdf

I’ve reviewed the brief. Opposing counsel makes three arguments: (1) no actual notice of the spill, (2) no constructive notice because plaintiff cannot prove how long the liquid was on the floor, and (3) the open and obvious doctrine bars recovery. Let me research counter-arguments.

Found 20 premises liability cases
Analyzed Markowitz v. Helen Homes of Kendall Corp., 826 So. 2d 256 (Fla. 2002)
Analyzed Minjarez v. Wal-Mart Stores, 363 F. Supp. 3d 763 (W.D. Tex. 2019)

I’ve identified four strong counter-arguments, each backed by caselaw:

Counter-ArgumentKey Authority
Mode of Operation
Self-serve produce areas create foreseeable spill hazards—notice can be imputed from the mode of operation without proof of actual or constructive notice.
Markowitz v. Helen Homes of Kendall Corp., 826 So. 2d 256 (Fla. 2002)
Circumstantial Evidence of Duration
Dirty footprints through the spill, discoloration of the liquid, and debris in the puddle are circumstantial evidence the spill existed long enough to charge the store with constructive notice.
Minjarez v. Wal-Mart Stores, 363 F. Supp. 3d 763 (W.D. Tex. 2019)
Open and Obvious Is Not a Complete Bar
The open and obvious doctrine does not automatically defeat a premises liability claim—it is a factor in comparative negligence, not a complete defense, particularly where the invitee’s attention was reasonably diverted.
Person-Thomas v. Quilliams-Noble Apartments, 45 N.E.3d 654 (Ohio Ct. App. 2015)
Failure to Produce Inspection Records
The store’s failure to produce evidence of its last inspection of the area creates an inference that it did not maintain a reasonable inspection schedule, supporting constructive notice.
Gaydos v. Grupe Real Estate Investors, 211 Ga. App. 811 (Ga. Ct. App. 1994)

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