Cooper v. Wal-Mart Stores, Inc. d/b/a Walmart

CourtDistrict Court, S.D. New York
DecidedJune 6, 2025
Docket7:24-cv-00205
StatusUnknown

This text of Cooper v. Wal-Mart Stores, Inc. d/b/a Walmart (Cooper v. Wal-Mart Stores, Inc. d/b/a Walmart) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cooper v. Wal-Mart Stores, Inc. d/b/a Walmart, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------------------------------------X

LAURA COOPER,

Plaintiff, OPINIO N AND ORDER -against- 24 Civ. 205 (JCM)

WAL-MART STORES, INC. d/b/a WALMART, and WAL-MART STORES EAST, LP,

Defendants.

--------------------------------------------------------------X

Plaintiff Laura Cooper (“Cooper” or “Plaintiff”) brought this action against Defendants Wal-Mart Stores, Inc. d/b/a Walmart, and Wal-Mart Stores East, LP (together, “Walmart” or “Defendants”) in the New York State Supreme Court, Orange County, to recover for personal injuries allegedly sustained as a result of a fall at Defendants’ Walmart store in Middletown, New York, on May 19, 2022. (Docket No. 1-1). Defendants removed the case to this Court based on diversity jurisdiction on January 10, 2024. (Docket No. 1). Presently before the Court is Defendants’ motion for summary judgment pursuant to Rule 56 of the Federal Rules of Civil Procedure (“Motion”). (Docket No. 16). Plaintiff opposed the Motion (“Opposition”) (Docket No. 27), and Defendants replied (“Reply”) (Docket No. 29). For the reasons set forth below, Defendants’ Motion is granted.1 0F I. BACKGROUND

The following facts are taken from Defendants’ Statement of Material Facts submitted pursuant to Local Rule 56.1 of the United States District Courts for the Southern and Eastern

1 This action is before the Court for all purposes on the consent of the parties, pursuant to 28 U.S.C. § 636(c) and Federal Rule of Civil Procedure 73. (Docket No. 11). Districts of New York (“Def. 56.1”), (Docket No. 19); Plaintiff’s Response to Defendants’ 56.1 Statement of Material Facts (“Pl. 56.1 Resp.”), (Docket No. 28); Defendants’ Response to Plaintiff’s Statement of Additional Material Facts (“Def. 56.1 Resp.”), (Docket No. 30); and the exhibits submitted by the parties in support of their statements. The facts are construed in the light most favorable to Plaintiff as the party opposing summary judgment. See Wandering Dago,

Inc. v. Destito, 879 F.3d 20, 30 (2d Cir. 2018). Any disputes of material fact are noted. On May 19, 2022, Plaintiff was shopping at the Middletown Walmart store. (Def. 56.1 ¶ 1; Pl. 56.1 ¶ 1). She fell near the self-checkout while rounding the corner to leave. (Def. 56.1 ¶ 2; Pl. 56.1 Resp. ¶ 2). The store manager described this area as “a high traffic area.” (Pl. 56.1 Resp. ¶ 21; Def. 56.1 Resp. ¶ 21). Prior to her fall, Plaintiff did not observe anything on the floor, and nothing had blocked her view of the floor. (Def. 56.1 ¶¶ 4-5; Pl. 56.1 Resp. ¶¶ 4-5). She was looking forward when her right foot slipped and her left leg went back. (Pl. 56.1 Resp. ¶ 19; Def. 56.1 Resp. ¶ 19; Pl. Dep. (Docket No. 17-1) at 34:23-24). Plaintiff maintains she “slipped and fell on a puddle of liquid.” (Pl. 56.1 Resp. ¶ 2). While Plaintiff was on the floor,

another customer stated to Plaintiff that there was clear liquid on the floor. (Def. 56.1 ¶ 6; Pl. 56.1 Resp. ¶ 6). Plaintiff claims she saw the puddle when she got up from the floor, (Pl. 56.1 Resp. ¶ 7), but Defendants contend that the other customer pointed out the puddle to Plaintiff, (Def. 56.1 ¶ 7). Plaintiff states that after she got up she observed a large, clear puddle that “was like splatter marks of something spilled.” (Def. 56.1 ¶ 8; Pl. 56.1 Resp. ¶ 8). The liquid did not contain any debris, track marks or footprints other than Plaintiff’s footprint. (Def. 56.1 ¶¶ 9-11; Pl. 56.1 Resp. ¶¶ 9-11). Plaintiff does not know how long the liquid was on the floor prior to her fall. (Def. 56.1 ¶ 13; Pl. 56.1 Resp. ¶ 13). Plaintiff contends there were approximately 35-40 front-end team associates working in the cashier and self-checkout areas. (Pl. 56.1 Resp. ¶ 23). Defendants counter that Walmart had 35-40 front-end team associates on its payroll, but they were not all necessarily working at the

time of the accident. (Def. 56.1 Resp. ¶ 23). Walmart employees who work in the self-checkout area are responsible for keeping their areas clean. (Pl. 56.1 Resp. ¶¶ 24, 27-29; Def. 56.1 Resp. ¶¶ 24, 27-29). They are supposed to clean up messes or call the maintenance team to clean up large spills. (Pl. 56.1 Resp. ¶¶ 25-26, 30-33; Def. 56.1 Resp. ¶¶ 25-26, 30-33). The Walmart manager also testified that when there is a spill in the self-checkout area, an associate would guard the spill until maintenance could come clean it up. (Pl. 56.1 Resp. ¶ 34; Def. 56.1 Resp. ¶ 34). Walmart’s surveillance video shows that the liquid on the floor was created by another customer at 12:57:26 p.m. (Def. 56.1 ¶ 15; Pl. 56.1 Resp. ¶ 15). That customer is holding an

object that drips liquid on the floor. (Pl. 56.1 Resp. ¶ 44; Def. 56.1 Resp. ¶ 44). Plaintiff contends that after the liquid dripped the video shows Walmart employees and patrons avoiding the puddle. (Pl. 56.1 Resp. ¶ 46). Defendants disagree and argue that no one can be seen intentionally avoiding the liquid. (Def. 56.1 Resp. ¶ 46). At 1:03:07 p.m., the video shows Plaintiff slip and fall, only five minutes and forty-one seconds after the liquid was spilled. (Def. 56.1 ¶¶ 14, 17; Pl. 56.1 Resp. ¶¶ 14, 17; Docket No. 26-2). At 1:04 p.m., the video shows a self- checkout employee taking paper towels from a nearby register and cleaning up the puddle. (Pl. 56.1 Resp. ¶ 54; Def. 56.1 Resp. ¶ 54; Docket No. 26-2). Walmart’s store manager Christopher Collins explained that self-checkout hosts were responsible for helping customers check out items and cleaning up messes they could see. (Docket No. 26-1 at 22:21-23:10). He said that if they “saw a spill [they] would guard it, call

maintenance, call someone, not leave it, and have somebody come there and clean it.” (Id. at 47:6-9). II. LEGAL STANDARD New York state law governs substantive slip and fall claims.2 However, federal law 1F applies to procedural aspects of the claim. Tingling v. Great Atl. & Pac. Tea Co., No. 02 Civ. 4196 (NRB), 2003 WL 22973452, at *2 (S.D.N.Y. Dec. 17, 2003) (“We find that the issue of what burden a movant for summary judgment bears when the ultimate burden of proof lies with the non-movant is procedural rather than substantive, under the distinction created by Erie R. Co. v. Tompkins, 304 U.S. 64 (1938) . . . and its progeny, and accordingly is subject to federal rather than state law.”) (citations omitted); see also Hanna v. Plumer, 380 U.S. 460, 465 (1965). Since the moving party’s burden of proof on a summary judgment motion is procedural, federal law governs. Hughes v. United States, No. 12 Civ. 5109 (CM), 2014 WL 929837, at *4 (S.D.N.Y. Mar. 7, 2014) (applying the federal burden of proof standard on a motion for summary judgment, explaining that “[e]ven though the substantive claims are governed under New York law, the procedural issues are determined under the federal standard”).

2 Because jurisdiction over this matter is based upon the parties’ diversity of citizenship, and because the accident occurred in New York, the parties agree that New York law governs the substantive claims. (Docket No. 18 at 4; Docket No. 27 at 7). The federal burden of proof on a motion for summary judgment differs from the corresponding standard under New York law in a slip-and-fall action. See, e.g., Tenay v.

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Cooper v. Wal-Mart Stores, Inc. d/b/a Walmart, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cooper-v-wal-mart-stores-inc-dba-walmart-nysd-2025.