Anthony Gilchrist v. Meldi Sub, LLC

CourtCourt of Appeals of Georgia
DecidedMarch 7, 2022
DocketA21A1678
StatusPublished

This text of Anthony Gilchrist v. Meldi Sub, LLC (Anthony Gilchrist v. Meldi Sub, LLC) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Anthony Gilchrist v. Meldi Sub, LLC, (Ga. Ct. App. 2022).

Opinion

FOURTH DIVISION DILLARD, P. J., MERCIER and PINSON, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules

March 7, 2022

In the Court of Appeals of Georgia A21A1678. GILCHRIST v. MELDI SUB, LLC et al.

PINSON, Judge.

Anthony Gilchrist was injured when he fell on a walkway on the side of a

building housing a sandwich shop and a convenience store. Based on the presence of

a protruding cleanout plug and the absence of a railing around the edge of the

walkway, he sued the building owner and the lessees who operated the stores for

negligence, negligence per se, and nuisance. The trial court granted summary

judgment in favor of the defendants. We affirm the trial court’s decision because the

undisputed evidence shows that these conditions were open and obvious to someone

exercising reasonable care under the circumstances. As a result, Gilchrist is deemed

to have had equal knowledge of the conditions that caused him to fall, which

precludes recovery here. Background

In February 2017, Gilchrist went for a walk into town from his Hancock

County home on the outskirts of Sparta.1 He was joined on his walk by a friend,

Tarsha Williams. The walk was for exercise, and Gilchrist did not plan to shop or

otherwise conduct business along the way.

Gilchrist was born with an eye condition called retinitis pigmentosa and is

legally blind. Gilchrist testified that he has never held a driver’s license because of

his visual impairment and has received Medicare and Social Security Disability

Insurance payments since 2004. That said, as of the time of his accident, he was able

to see silhouettes of people, cars, animals, and “things of that nature.” He was also

able to see the ground well enough to avoid uneven pavement, tree limbs, and other

obstructions. Before his accident, he had never used a cane or a walking stick.

As the pair approached town, they stopped to talk to an acquaintance who was

pumping gas at an Exxon station. After a few minutes, Williams left to continue

walking, but Gilchrist remained, telling Williams he would catch up with her. After

finishing his conversation, Gilchrist walked from the gas pump to the sidewalk that

1 In reviewing summary judgment orders, we view the evidence in the record in the light most favorable to the party opposing summary judgment. Lau’s Corp. v. Haskins, 261 Ga. 491, 491 (405 SE2d 474) (1991).

2 ran along the storefront of the gas station’s convenience store and an adjoining

Subway shop. He chose that route because he was attempting to avoid the cars driving

through the parking lot. Gilchrist did not enter either the convenience store or the

Subway.

Once on the sidewalk, Gilchrist walked along the storefront to the end of the

building and then turned to his left, believing he had reached the sidewalk running

parallel to the street. He intended to cross that street, and he was paying attention to

the cars on the street, looking for a break in the traffic. But rather than being on the

sidewalk, Gilchrist was on the service walkway next to the building, which was

elevated a few feet above ground level and had no railing.2 Gilchrist took several

steps and then stumbled, fell off the walkway, and landed on the ground below,

sustaining various injuries.

Gilchrist testified that he did not know what caused him to fall. But an

eyewitness said that Gilchrist “tripped over . . . a clean-out plug protruding up in the

2 A photograph of the accident scene shows the walkway, which sits atop a retaining wall extending from the parking lot toward the back of the building. The height of the wall—and thus the distance from the walkway to the ground below—increases as the ground level slopes downward. An expert who examined the property testified that, where Gilchrist fell, the walkway was elevated from 40 to 58 inches above the ground level.

3 sidewalk.” A photograph of the site shows a pipe-like object protruding from the

middle of the walkway. An expert witness testified that this protruding “plumbing

clean-out plug,” as well as the lack of a railing on the elevated walkway, are

violations of certain building codes and the Americans with Disabilities Act.3

Gilchrist sued the owner of the property, Sky Property Management, LLC, and

lessees Dahi Mahi, Inc., which operated the Exxon, and Meldi Sub, LLC, which

operated the Subway. The operative complaint alleges three claims: (1) negligence

based on the absence of a railing on the walkway and the lack of signs warning of the

danger; (2) negligence per se based on the “dangerous condition” created by the

walkway, in violation of the Americans with Disabilities Act, the Rehabilitation Act

of 1973, and the Georgia Access to Use of Public Facilities by Persons with

Disabilities Act; and (3) nuisance.

3 This opinion was given an affidavit submitted by Timothy Thomas, Public Works Director of the City of Milledgeville, who visited the site after the accident. Thomas attested that the absence of “edge protection” violated “Section 1015, Guards (IBC) International Building Code” ; that the “plumbing cleanout plug” projected “above the sidewalk surface beyond the allowed maximum height” prescribed in “Section 303, (ICC) International Code Council, (ANSI) American National Standard Institute” ; and that “[t]hese violations also are violations of [the] ADA[.]”

4 All three defendants moved for summary judgment. Following a hearing, the

trial court granted the defendants’ motions in three separate orders. In each order, the

court concluded that, Gilchrist was, at best, a licensee to whom the defendants could

be liable only for willful or wanton injury, because he was not a customer on the

property at the time of his injury. See OCGA § 51-3-2 (providing that premises

owners are liable to licensees “only for willful or wanton injury”). Finding no

evidence of any intentional or reckless conduct by the defendants that would give rise

to a finding of “willful or wanton injury,” the court concluded that there was no basis

for imposing liability. The court’s orders are silent on Gilchrist’s claims for

negligence per se and nuisance. Gilchrist appealed.

Discussion

On appeal, orders granting or denying summary judgment are reviewed de

novo. Johnson v. Omondi, 294 Ga. 74, 75 (751 SE2d 288) (2013). Summary judgment

is appropriate where no genuine issues of material fact remain, such that the party

seeking summary judgment is entitled to judgment as a matter of law. Id.

1. Gilchrist first contends that the trial court erred in granting summary

judgment because there is a genuine issue of fact as to whether the defendants

5 breached their duty to prevent willful or wanton injury to him.4 Gilchrist does not

appear to dispute that he was a licensee on the property at the time of his accident, or

that as a licensee, he was owed by the defendants only the duty to avoid inflicting

willful or wanton injury. See OCGA § 51-3-2. Gilchrist contends that the defendants

in fact breached that duty by maintaining the walkway in the condition it was in at the

time of the accident.

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Anthony Gilchrist v. Meldi Sub, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/anthony-gilchrist-v-meldi-sub-llc-gactapp-2022.