Campos v. Jewel Food Stores Inc

CourtDistrict Court, N.D. Illinois
DecidedFebruary 2, 2025
Docket1:24-cv-00382
StatusUnknown

This text of Campos v. Jewel Food Stores Inc (Campos v. Jewel Food Stores Inc) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Campos v. Jewel Food Stores Inc, (N.D. Ill. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

MARY ELLEN CAMPOS ) ) Plaintiff, ) No. 24 C 382 ) v. ) Judge Robert W. Gettleman ) NEW ALBERTSONS L.P. D/B/A, ) JEWEL-OSCO, JEWEL FOOD STORES, INC., ) ROLLING FRITO-LAY SALES, LP ) Defendants. )

MEMORANDUM OPINION & ORDER Plaintiff brings this six-count amended complaint against New Albertsons L.P. D/B/A Jewel Osco, Jewel Food Stores Inc. (“Jewel”), and Rolling Frito-Lay Sales LP (“Frito-Lay”). Relevant here are Count V, which alleges negligence against Frito-Lay, and Count VI, which alleges negligent supervision and training against Frito-Lay. Frito-Lay moves for summary judgement on the counts against it. For the reasons discussed below, the court denies Frito-Lay’s motion for summary judgement. (Doc. 67).

BACKGROUND Plaintiff Mary Ellen Campos tripped and fell on a pallet guard after entering a Jewel- Osco grocery store. She allegedly suffered serious injuries, including multiple fractures and injuries to her nervous system. This is a case about whose fault that is. On December 29, 2023, at approximately 11:38 a.m., plaintiff entered the west entrance of the Jewel-Osco grocery store located at 30 Danada Square West, Wheaton, Illinois. Upon entering the west entrance of the Jewel, customers are faced with aisles that run between rows of shelves containing grocery products. At the ends of some of the rows of shelves are product displays, familiar to anyone who shops in American grocery stores, oriented perpendicular to the aisles. These are known in the grocery industry as “end caps.”

The end caps at the Jewel consisted of boxes of product stacked atop pallets and a “pallet guard,” a rectangular black plastic frame on the floor that surrounds the pallets. The pallet guards used at the Jewel are approximately one foot tall and are modifiable, meaning that their perimeter can be adjusted depending on the size of the end cap. On December 29, 2023, at the Jewel, one such end cap was situated at the end of the row directly in front of the west entrance. The pallet guard was set up to fit two pallets side-by-side. At 11:38 a.m., the right half of the

end cap was empty, while the left half was stacked a few feet high with product. The right half of the end cap was empty because early that morning, a Frito-Lay employee was instructed by Jewel to remove the pallet of Tostitos (a Frito-Lay product) that were then occupying the right half of the display. As directed, the Frito-Lay employee did so at approximately 7:05 a.m. To remove the product, the Frito-Lay employee disconnected the panel

at the short end of the rectangular pallet guard, removed the Tostitos using a pallet jack, and put the pallet guard panel back in its place. The entire operation took approximately three minutes. From that point until plaintiff’s fall at 11:38 a.m., the right half of the pallet guard remained empty. In that time, multiple Jewel employees walked by the half-empty end cap. LEGAL STANDARD

Summary judgment is proper when “the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a). The movant bears the burden, and the court must view all facts in the light most favorable to the nonmovant and draw all reasonable inferences in their favor. See Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 587 (1986). But the nonmovant must do more than raise “some metaphysical doubt as to the material facts.” Id. at 586. Rather, the nonmovant “must present affirmative evidence in order to defeat a properly supported motion for summary

judgment.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 257 (1986). DISCUSSION

Under Illinois law, the elements of a negligence cause of action are: (1) a duty owed by the defendant to the plaintiff; (2) a breach of that duty; and (3) an injury proximately caused by the breach. Johnson v. Armstrong, 211 N.E. 3d 355, 371 (Ill. 2022). Defendant moves for summary judgement on Counts V and VI of the amended

complaint. Count V alleges that Frito-Lay negligently created the dangerous condition that caused plaintiff’s fall. Count VI alleges that Frito-Lay negligently supervised and trained its employees, thus causing its employee to negligently create the dangerous condition. Frito-Lay argues that it owed no duty to the plaintiff. Frito-Lay is correct that “where there is no duty, there is no liability.” Bucheleres v. Chicago Park District, 665 N.E.2d 826, 832

(Ill. 1996). According to Frito-Lay, since the pallet guards are the property of Jewel, the duty to plaintiff was owed by Jewel and not Frito-Lay, because “Jewel, which controlled the store, did not consider [an empty pallet guard] a hazard.” As to the negligent supervision and training count, Frito-Lay argues that it has no duty to train its employees regarding the pallet guards

owned by Jewel. Plaintiff argues that Frito-Lay owed a duty to plaintiff that is independent of the duty owed by Jewel. Plaintiff maintains that Frito-Lay created the dangerous condition that injured plaintiff. Plaintiff argues that regardless of whether Jewel negligently failed to remedy the condition that Frito-Lay created, Frito-Lay breached its duty of reasonable care in executing its

work. Plaintiff further argues that summary judgement is not appropriate because there are material facts in dispute. The crucial fact in dispute, according to plaintiff, is whether removing the empty pallet guard was the responsibility of Jewel, Frito-Lay, or shared between the two.

Plaintiff is correct that Frito-Lay could still owe a duty to plaintiff even if Jewel, the possessor of the premises, also owed a duty to plaintiff. “It is firmly established in Illinois that a party that creates a dangerous condition will not be relieved of liability because that party does not own or possess the premises upon which the dangerous condition exists.” Corcoran v. Village of Libertyville, 383 N.E.2d 177, 179 (Ill. 1978). The Restatement (Second) of Torts § 383, which has been adopted by Illinois courts, explains that “[o]ne who does an act or carries on

an activity upon land on behalf of the possessor is subject to the same liability, and enjoys the same freedom from liability, for physical harm caused thereby to others upon and outside of the land as though he were the possessor of the land.” See e.g., Studer v. Illinois Scale Company, 192 N.E. 3d 774, 780 (Ill. App. 3d 2021); Jones v. Live Nation Entertainment, Inc., 63 N.E. 3d 959, 971 (Ill. App. 1st 2016). Therefore, even if Jewel had a duty to plaintiff as the possessor of the premises where she was injured, Frito-Lay could owe a duty to plaintiff independently.

Frito-Lay’s argument has a second angle: Frito-Lay did not “control” the black pallet guard owned by Jewel and thus it could not have and did not create the dangerous condition. Frito-Lay contends that it did not create the dangerous condition because the black pallet guard, which was owned by Jewel, was left in the exact place the Frito-Lay employee found it. In support of this argument, defendant offers this quote: “It is not [the agent’s] contract with the principal which exposes him to, or protects him from, liability to third persons, but his common-

law obligation to so use that which he controls as not to injure another.” Schur v. L.A.

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Related

Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Schur v. L.A. Weight Loss Centers, Inc.
577 F.3d 752 (Seventh Circuit, 2009)
Corcoran v. Village of Libertyville
383 N.E.2d 177 (Illinois Supreme Court, 1978)
Bucheleres v. Chicago Park District
665 N.E.2d 826 (Illinois Supreme Court, 1996)
Bruns v. City of Centralia
2014 IL 116998 (Illinois Supreme Court, 2014)
Jones v. Live Nation Entertainment, Inc.
2016 IL App (1st) 152923 (Appellate Court of Illinois, 2016)
Johnson v. Armstrong
2022 IL 127942 (Illinois Supreme Court, 2022)
Studer v. Central Illinois Scale Co.
2021 IL App (3d) 200277 (Appellate Court of Illinois, 2021)

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Campos v. Jewel Food Stores Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/campos-v-jewel-food-stores-inc-ilnd-2025.