Anna L. Pistorius v. Higbee Louisiana, LLC, d/b/a Dillard's

CourtLouisiana Court of Appeal
DecidedFebruary 8, 2023
Docket54,780-CA
StatusPublished

This text of Anna L. Pistorius v. Higbee Louisiana, LLC, d/b/a Dillard's (Anna L. Pistorius v. Higbee Louisiana, LLC, d/b/a Dillard's) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Anna L. Pistorius v. Higbee Louisiana, LLC, d/b/a Dillard's, (La. Ct. App. 2023).

Opinion

Judgment rendered February 8, 2023. Application for rehearing may be filed within the delay allowed by Art. 2166, La. C.C.P.

No. 54,780-CA

COURT OF APPEAL SECOND CIRCUIT STATE OF LOUISIANA

*****

ANNA L. PISTORIUS Plaintiff-Appellant

versus

HIGBEE LOUISIANA, LLC, d/b/a Defendant-Appellee DILLARD’S

Appealed from the First Judicial District Court for the Parish of Caddo, Louisiana Trial Court No. 613,599

Honorable Ramon Lafitte, Judge

BROUSSARD & NEWLEN FIRM LLC Counsel for Appellant By: Christopher D. Broussard

BLANCHARD, WALKER, O’QUIN Counsel for Appellee & ROBERTS By: Timothy R. Wynn

Before PITMAN, COX, HUNTER, MARCOTTE, and MOORE (Ad Hoc), JJ.

MARCOTTE, J., dissents. MOORE, J. (Ad Hoc)

This is an appeal of a summary judgment granted in the First Judicial

District Court, Caddo Parish, the Honorable Ramon Lafitte presiding. While

walking intently down the main aisle in a department store on her way to the

shoe section, the plaintiff, Anna Pistorius (hereinafter, “Ms. Pistorius”),

tripped and fell over a large, low profile, flatbed cart parked on the right side

of the aisle located alongside the front of a display counter. She sued the

store owner, Higbee Louisiana, LLC, d/b/a Dillard’s (“Dillard’s), for

damages arising from the injuries she sustained from the fall. Dillard’s

moved for summary judgment alleging that the flatbed cart in the aisle was

an “open and obvious” condition, and therefore did not pose an unreasonable

risk of harm to the plaintiff. After oral argument, the court rendered

judgment for Dillard’s and dismissed the petition.

This appeal followed. We reverse and remand to the trial court for

further proceedings.

FACTS

Ms. Pistorius was injured on New Year’s Day, 2018, at a Dillard’s

department store in Shreveport when she tripped and fell over a stocking cart

parked on the main aisle in the men’s department. Although New Year’s

Day is typically a holiday, Dillard’s has held an annual New Year’s Day sale

for many years that is quite popular in the Shreveport area, drawing large

throngs of shoppers into the store for the one-day sale. Ms. Pistorius went to

the store with her best friend, Jill Richardson. The pair arrived at the store

around 10:30 a.m., entering the store through the men’s department

entrance. The entrance main aisle in the men’s department leads to a large

octagonal-shaped junction in the store where the escalators are located and

connects customers to the other main aisles on the ground floor that lead to

other departments in the store.

Ms. Pistorius testified at her deposition that she was bound for the

shoe department when she tripped and fell over a large, empty, flatbed

stocking cart that was parked lengthways on the right side of the 10-foot

wide aisle. The horizontal bed of the cart has a low profile with wheels

beneath, the bed raised approximately 6 to 8 inches off the floor. One end of

the cart has a waist-high handle in the shape of an upside-down “U,” with

three flat bars connecting the two vertical stems of the “U.” From the

photograph supplied, the bed of the cart appears to be made of wooden

planks.

The visual evidence submitted by the parties include photographs of

the cart near the location where the accident occurred; however, Ms.

Pistorius disputes the direction the cart is facing in the photograph and the

color of the handle. There are also several hours of video of the store scene

prior to the sale as well as video footage of the actual accident from a

location behind the counter where the cart was parked. The store scenes

depict very crowded, chaotic scenes of masses of shoppers jostling for

products on countertops, tables, hangers, and displays. The aisle in which

the accident occurred is depicted as busy with customers walking intently

toward the various destinations, but is far less crowded, and could be

described as a fairly orderly procession. The location of the cart in the aisle

is not visible in the video due to the display case blocking the camera view.

2 Ms. Pistorius and the other customers walking through the scene are visible

from the waist up only.

As previously noted, the aisle on which Ms. Pistorius was walking

opens into the junction area where customers must go to the right or the left

or to the escalator. As Ms. Pistorius neared the end of the aisle, she turned

momentarily to look behind her, turned back around, and immediately

dropped from sight. Obviously, she tripped over the cart at that point. Ms.

Richardson said that Ms. Pistorius tripped over the front corner of the flatbed

cart. The flatbed cart is depicted in photos provided by Dillard’s, but Ms.

Pistorius contends these are not accurate because of the direction of the cart

in the photo, the color of the handle, and other details.

Dillard’s filed a motion for summary judgment alleging that there

were no material facts in dispute, and the location and size of the flatbed cart

were “open and obvious,” and therefore, under the open and obvious

doctrine, the flatbed cart did not pose an unreasonable risk of harm to the

plaintiff. After the case was argued, the court rendered judgment as prayed

for, giving the following reasons:

The only issue in this motion for summary judgment is whether or not

there is a genuine issue of fact as to whether the object, a stocking cart over

which plaintiff tripped and fell, was open and obvious. The court said that it

had reviewed all the attachments, including the USB drive with a video (of

the incident), and had reviewed the cases argued by the parties, namely,

Russell v. Morgan’s Best Way of La., LLC, 47,914 (La. App. 2 Cir. 4/10/13),

113 So. 3d 448, Chatman v. Home Depot USA, Inc., 2009 WL 10697804

(W.D. La. 5/29/2009), Standifer v. Circle K Stores, Inc., 2015 WL 2452428

(W.D. La. 5/21/15), and Perrin v. Oschner Baptist Med. Ctr., 2019-0265 3 (La. App. 4 Cir. 8/7/19), 2019 WL 3719546, writ denied, 19-01557 (La.

11/25/19), 283 So. 3d 495. After review of those cases, the court concluded

that Russell and Chatman were most relevant. The court read the following

passages that he found controlling from those two cases:

From Chatman:

In general, defendants may have no duty to protect against an open and obvious hazard. If the facts on a particular case show that the complained of conditions should be obvious to all, not just to the plaintiff, but to all, the condition may be— may not be unreasonably dangerous and the defendant may not owe a duty to the plaintiff.

The degree to which a potential victim may observe a danger is one factor in the determination of whether the condition is unreasonably dangerous. A landowner is not liable for an injury that results from a condition that should have been observed by the individual and the exercise of reasonable care or was as obvious to a visitor as it was to a landowner. A pedestrian has a duty to see that which should have been seen and is bound to observe whether the pathway is clear.

From Russell:

Clearly, a single cart empty of any merchandise and located along a store aisle would be an obstacle that would be obvious to a shopper unless such cart was located and placed where the shopper might unexpectedly encounter it and trip.

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Bluebook (online)
Anna L. Pistorius v. Higbee Louisiana, LLC, d/b/a Dillard's, Counsel Stack Legal Research, https://law.counselstack.com/opinion/anna-l-pistorius-v-higbee-louisiana-llc-dba-dillards-lactapp-2023.