Bernardo v. Mohegan Tribal Gaming Authority

7 Am. Tribal Law 380, 3 G.D.R. 44
CourtMohegan Gaming Disputes Trial Court
DecidedFebruary 8, 2007
DocketGDTC-T-05-114-FOE
StatusPublished

This text of 7 Am. Tribal Law 380 (Bernardo v. Mohegan Tribal Gaming Authority) is published on Counsel Stack Legal Research, covering Mohegan Gaming Disputes Trial Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bernardo v. Mohegan Tribal Gaming Authority, 7 Am. Tribal Law 380, 3 G.D.R. 44 (Mo. 2007).

Opinion

BACKGROUND

EAGAN, Judge.

The case was tried to the Gaming Disputes Court, at which time seven witnesses [382]*382testified and multiple exhibits entered into the record.

The issues in this case are predominantly factual, rather than legal in nature. According to the plaintiff, the preponderance of the evidence introduced at trial establishes that on February 25, 2005, the plaintiff and his brother arrived at the Mohegan Sun Casino mid-afternoon where they parked on the 5th floor of the Riverview Garage.

At the time, the 5th level of the garage appeared clean of snow and ice. However, there were mounds of snow piled up against the wall of the garage which had been plowed there by the defendant. The afternoon was partly sunny.

At approximately 8:00 p.m., Mr. Bernardo and his brother left the Casino and took the elevator back up to the 5th level of the garage. As the plaintiff walked to his car, he slipped and fell on ice, which he did not see prior to his fall. The ice was the result of the snow piled up against the garage that melted as the temperature rose and then refroze in the evening. After his fall, plaintiff was unable to move, was in excruciating pain, and was eventually transported by ambulance to the William Backus Hospital in Norwich, Connecticut.

The defendant does not dispute that plaintiff slipped and fell on ice when walking to his car parked on the 5th floor of the Riverview Garage. Defendant also does not dispute that plaintiff was injured as a result of the fall.

Instead, defendant argues that the evidence shows the Riverview Garage was closed to the public throughout February 25, 2005 due to a prior snowstorm. Therefore, the plaintiff was a trespasser, or at best a licensee, at the time he fell.

Defendant also claims that plaintiff did not meet his burden of proof of showing that the ice remained on the garage floor beyond a reasonable time allowable to remediate the icy condition. Defendant further contends that plaintiff failed to meet its burden of establishing that it had actual or constructive notice of the ice. Additionally, defendant argues that it used reasonable care in maintaining the roof parking area.

Finally, defendant argues that the plaintiff was negligent in not observing the area of ice or, if he did observe it, negligent in proceeding to walk on it.

FINDING OF FACTS

1. On February 25, 2005, the plaintiff, accompanied by his brother, drove to the Mohegan Sun Casino where he parked his car on the 5th floor of the Riverview Garage at approximately 2:00-3:00 p.m.

2. February 25, 2005, was a generally fair day, partly sunny and, at times cloudy, with temperatures at or above freezing in the afternoon in the Montville/Mohegan Sun Casino area.

3. On February 24, 2005, there had been a snowfall of between 8-1/2 and 9-1/2 inches in the area.

4. When the plaintiff entered the Riv-erview Garage, there were no barricades to the entranceway, and there were other patrons’ cars parked in the garage, including on the 5th floor.

5. The plaintiff parked his car close to the entrance way to the elevators to the Casino in the handicapped parking area on the 5th level.

6. At the time the plaintiff parked his car, the garage floor was clean of any ice or snow.

7. At the time the plaintiff parked his car, there were mounds of snow piled up against the wall of the 5th floor as a result [383]*383of the defendant’s plowing of the snow from the prior snow storm.

8. By 6:00 p.m., on February 25, 2005, the temperature in the Montville/Mohegan Sun Casino area dropped to below freezing.

9. At approximately 8:00 p.m. on February 25, 2005, the plaintiff and his brother took the elevator from the Casino back up to the 5th level of the garage.

10. The plaintiff exited onto the paved section of the lot and began walking to his car.

11. As he approached the rear of the car, the plaintiff slipped and fell on ice.

12. The snow that had been plowed up into piles against the garage wall melted during the daytime and refroze as it ran off when the temperature dropped to below freezing.

13. The plaintiff did not see the ice that caused him to slip and fall, before he stepped on it.

14. The 5th floor of the Riverview Garage had not been sanded, salted or otherwise treated at the time the plaintiff fell.

15. After he fell, the plaintiff was unable to move and was in excruciating pain in his right hip and wrist.

16. Because the plaintiff was in so much pain after his fall, an agent of the Mohegan Tribal Protective Services was unable to take his statement at that time.

17. The plaintiff was taken by ambulance to the William W. Backus Hospital in Norwich, Connecticut, where he stayed for approximately 4 days.

18. Following his discharge from the hospital, plaintiff was an inpatient at the Montowese Health and Rehabilitation Center for 19 days.

19. Upon his discharge from Mon-towese to his home, plaintiff was prescribed the services of a visiting nurse for another 30 days.

20. Plaintiffs total medical bills incurred as a result of his fall at the Casino on February 25, 2005 were $50,415.05.

21. As a result of the fall, the plaintiff suffered an intertrochanteric fracture of his right hip and a fracture of his right distal radius.

22. Because of his hip injury, plaintiff underwent a surgical procedure in which a rod is nailed into the bone with fenestra-tions in the rod for screws to stabilize the fracture.

23. As a result of the accident, plaintiff suffered a permanent loss of 7% of his right lower extremity and a 5% loss to his right wrist.

24. At the time of his fall, plaintiff was 65 years old.

25. Prior to his fall at the Casino, the plaintiff led an active life, assisted his son in his restaurant business and considered opening a restaurant himself, or taking over one owned by his son.

26. Prior to his fall, plaintiff did have some back pain and, on occasion, used a cane, which he was not using on February 25, 2005.

27. Since the accident, the plaintiff has experienced significant hip and groin pain as a result of the rod, which cannot be removed, as well as some pain in his right wrist when it is subject to extreme movement.

28. As a result of the injuries sustained from the accident, the plaintiff now spends most of his time at home, watching television.

DISCUSSION

1. Standard of Care

At the time of plaintiffs fall on February 25, 2005, Mohegan Tribal Ordinance [384]*384(“MTO”) 2001-07, known as the Mohegan Trots Code, was in effect1 and governs this action.

The Mohegan Torts Code: applies to “any and all tort claims arising on the Mohegan Reservation that may be brought against the MTO A ...” 2001-07, Sec. 4(c); and is “the exclusive means of adjudication of claims brought against the MTGA ...” 2001-07, Sec. 4(D) The plaintiffs claim is clearly a tort claim asserting negligence in connection with the MTGA’s maintenance of the Riverview Garage. Negligence was defined in M.T.O.2001-07, Sec. 5 A(15), to mean

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Cite This Page — Counsel Stack

Bluebook (online)
7 Am. Tribal Law 380, 3 G.D.R. 44, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bernardo-v-mohegan-tribal-gaming-authority-mohegangct-2007.