Caudill v. Walmart Stores East, LP

CourtDistrict Court, E.D. Kentucky
DecidedFebruary 28, 2025
Docket5:23-cv-00321
StatusUnknown

This text of Caudill v. Walmart Stores East, LP (Caudill v. Walmart Stores East, LP) is published on Counsel Stack Legal Research, covering District Court, E.D. Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Caudill v. Walmart Stores East, LP, (E.D. Ky. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF KENTUCKY CENTRAL DIVISION (at Lexington)

PHYLLIS ANNETTE CAUDILL, ) ) Plaintiff, ) Civil Action No. 5: 23-321-DCR ) V. ) ) WALMART STORES EAST, L.P., ) MEMORANDUM OPINION ) AND ORDER Defendant. )

*** *** *** *** This matter is pending for consideration of Defendant Walmart Stores East, L.P.’s Motion for Partial Summary Judgment concerning the plaintiff’s claim for punitive damages. [Record No. 38] The motion will be granted for the reasons outlined below. I. On September 7, 2022, Plaintiff Phyllis Caudill visited the Walmart store in Richmond, Kentucky, to purchase an anniversary card for her significant other, Mark Cole. [Record No. 38-3] Upon entering the store during the noon hour, Caudill went to Aisle F14 (the greeting card aisle) where she slipped and fell on grapes and water on the floor. Caudill claims that she landed in a split position, which caused injury to her sacrum, left foot, and head. [Record No. 39-1] She also claims that she was bleeding from her elbow, foot, and head because of the fall. [Id.] Following the fall, Caudill contacted Cole to ask that he pick her up. [Id.] While she was waiting, the store manager and several associates tended to her care. [Id.] The plaintiff testified that the associates were “very empathetic and worried” and that the manager, Tony, “was very nice.” [Id.] Caudill further testified that the Walmart employees helped her get up, “asked if she needed an ambulance, brought her a chair, and assisted her to the car.” [Id.] When asked in her deposition whether she took any issue with the employee’s actions, the

plaintiff stated that she did not and that she just wanted her medical bills to be covered. [Id.] Caudill did not go to the hospital immediately because she believed she had injured her tailbone and was under the impression that “there’s not much you can do if you break your tailbone.” [Id.] Eventually, however, she went to the emergency room on September 16, 2022. [Record No. 38-3] II. Summary judgment is appropriate if, based on the pleadings, discovery materials, and

other documents in the record, there is no genuine dispute as to any material fact, and the moving party is entitled to judgment as a matter of law. Fed. R. Civ. P. 56(a). The court may not weigh the evidence or make credibility determinations but must determine “whether the evidence presents a sufficient disagreement to require submission to a jury or whether it is so one-sided that one party must prevail as a matter of law.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 251–52 (1986); see also Moran v. Al Basit LLC, 788 F.3d 201, 204 (6th Cir.

2015). In reviewing a motion for summary judgment, the court must view all facts and draw all reasonable inferences in a light most favorable to the nonmoving party. See Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 587–88 (1986). If “the record taken as a whole could not lead a rational tried of fact to find for the nonmoving party, there is no genuine issue for trial,” and summary judgment is proper. Matsushita Elec. Indus. Co., Ltd. V. Zenith Radio Corp., 475 U.S. 574, 587 (1986). The moving party has the initial burden of demonstrating the basis for its motion and identifying those parts of the record that establish the absence of a genuine issue of material fact. Chao v. Hall Holding Co. Inc., 285 F.3d 415, 424 (6th Cir. 2002). The moving party can meet its burden by showing “there is an absence

of evidence to support the non-moving party’s case.” Celotex Corp. v. Catrett, 477 U.S. 317, 323-25 (1986). If a moving party can meet its burden of production, the opponent “must do more than simply show that there is some metaphysical doubt as to the material facts” and “must come forward with specific facts showing that there is a genuine issue for trial.” Matsushita Elec. Indus. Co., Ltd. V. Zenith Radio Corp., 475 U.S. 574, 587 (1986). If the non-moving party cannot “make a showing sufficient to establish the existence of an element essential to that

party’s case, and on which that party will bear the burden of proof at trial,’ the moving party is entitled to judgment as a matter of law.” [Id.] III. The defendant has moved for summary judgment regarding the plaintiff’s punitive damages claim. Punitive damages are damages “other than compensatory and nominal damages, awarded against a person to punish and to discourage him and others from similar

conduct in the future.” KRS § 411.184(1)(f). Under Kentucky law, “[a] plaintiff shall recover punitive damages only upon proving, by clear and convincing evidence, that the defendant from whom such damages are sought acted toward the plaintiff with oppression, fraud or malice.” KRS § 411.184(2). Clear and convincing evidence “requires a party with the burden of proof to produce evidence substantially more persuasive than preponderance of the evidence but not beyond a reasonable doubt.” Glodo v. Evans, 474 S.W.3d 550, 554 (Ky. 2015). The burden is on the plaintiff to show the defendant acted toward the plaintiff “with oppression, fraud, or gross negligence.” Williams v. Wilson, 972 S.W.2d 260 (Ky. 1998). Gross negligence “is a conscious and voluntary act or omission which is likely to result

in grave injury when in face of clear and present danger of which the alleged tortfeasor is aware.” Sparks v. Re/Max Allstar Realty, Inc., 55 S.W.3d 343, 348 (Ky. Ct. App. 2000). It is a “wanton or reckless disregard for the lives, safety, or property of others.” Saint Joseph Healthcare, Inc. v. Thomas, 487 S.W.3d 864, 870 (Ky. 2016). Courts examine whether the underlying conduct is ‘“outrageous’ in character, not whether the injury was intentionally or negligently inflicted.” Horton v. Union Light, Heat & Power Co., 690 S.W.2d 382, 389 (Ky. 1985).

Here, the plaintiff has failed to offer a sufficient basis to support a claim for punitive damages. Caudill’s testimony demonstrates the employees at Walmart acted with ordinary care in tending to her following the slip and fall. [Record No. 38-3] Further, the record is devoid of any evidence that the defendant’s employees knew of the spilled water and grapes and chose not to take any action to clean up the mess, thereby intentionally exposing Caudill to an unreasonable risk.

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Related

Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Chao v. Hall Holding Company, Inc.
285 F.3d 415 (Sixth Circuit, 2002)
Horton v. Union Light, Heat & Power Co.
690 S.W.2d 382 (Kentucky Supreme Court, 1985)
Lanier v. Wal-Mart Stores, Inc.
99 S.W.3d 431 (Kentucky Supreme Court, 2003)
Sparks v. Re/Max Allstar Realty, Inc.
55 S.W.3d 343 (Court of Appeals of Kentucky, 2000)
Williams v. Wilson
972 S.W.2d 260 (Kentucky Supreme Court, 1998)
Jeffrey Moran v. Al Basit LLC
788 F.3d 201 (Sixth Circuit, 2015)
Glodo v. Evans
474 S.W.3d 550 (Court of Appeals of Kentucky, 2015)
Saint Joseph Healthcare, Inc. v. Thomas
487 S.W.3d 864 (Kentucky Supreme Court, 2016)

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