Del Carmen Guido v. Albertson's LLC

CourtDistrict Court, D. Nevada
DecidedDecember 12, 2024
Docket2:23-cv-01229
StatusUnknown

This text of Del Carmen Guido v. Albertson's LLC (Del Carmen Guido v. Albertson's LLC) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Del Carmen Guido v. Albertson's LLC, (D. Nev. 2024).

Opinion

1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 MARIA DEL CARMEN GUIDO, Case No.: 2:23-cv-01229-APG-NJK

4 Plaintiff Order Granting Partial Summary Judgment for Defendant and Denying 5 v. Plaintiff’s Countermotion for Sanctions

6 ALBERTSON’S LLC, [ECF Nos. 22, 23]

7 Defendant

8 Plaintiff Maria Del Carmen Guido sued Albertson’s LLC after she slipped and fell in an 9 Albertson’s store’s floral department, allegedly due to water on the floor. She brought claims for 10 premises liability negligence and negligent hiring, training, supervision, and retention. 11 Albertson’s moves for summary judgment on all claims. Guido argues that Albertson’s either 12 failed to adequately protect against known hazards or caused the hazard by using a leaky bucket. 13 Guido also claims that Albertson’s spoliated evidence and moves for sanctions. 14 The parties are familiar with the facts, so I do not set them forth in full here. I grant 15 Albertson’s motion for summary judgment for the negligent hiring, training, supervision, and 16 retention claims. But I deny Albertson’s motion for judgment on the negligence claim because 17 genuine disputes of material fact remain regarding the cause and duration of the water on the 18 floor. I deny Guido’s motion for sanctions. 19 I. DISCUSSION 20 Summary judgment is appropriate if the movant shows “there is no genuine dispute as to 21 any material fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 22 56(a). A fact is material if it “might affect the outcome of the suit under the governing law.” 23 1 Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). A dispute is genuine if “the evidence 2 is such that a reasonable jury could return a verdict for the nonmoving party.” Id. 3 The party seeking summary judgment bears the initial burden of informing the court of 4 the basis for its motion and identifying those portions of the record that demonstrate the absence

5 of a genuine issue of material fact. Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). The 6 burden then shifts to the non-moving party to set forth specific facts demonstrating there is a 7 genuine issue of material fact for trial. Sonner v. Schwabe N. Am., Inc., 911 F.3d 989, 992 (9th 8 Cir. 2018) (“To defeat summary judgment, the nonmoving party must produce evidence of a 9 genuine dispute of material fact that could satisfy its burden at trial.”). I view the evidence and 10 reasonable inferences in the light most favorable to the non-moving party. Zetwick v. Cnty. of 11 Yolo, 850 F.3d 436, 440-41 (9th Cir. 2017). 12 A. Negligent hiring, training, supervision, and retention (Counts 2, 3, and 4) 13 Albertson’s argues that Guido has failed to identify any specific employee who was unfit 14 and failed to offer any evidence that Albertson’s was negligent in hiring, training, supervising, or

15 retaining any employee. Guido does not respond to Albertson’s motion on these claims. 16 Because Guido bears the burden of proof at trial, Albertsons “need only prove that there is an 17 absence of evidence to support [Guido’s] case.” In re Oracle Corp Sec. Litig., 627 F.3d 376, 387 18 (9th Cir. 2010); Celotex, 477 U.S. at 325 (stating that “the burden on the moving party may be 19 discharged by ‘showing’—that is, pointing out to the district court—that there is an absence of 20 evidence to support the nonmoving party’s case”). Because Guido did not respond to this 21 portion of Albertson’s motion, she did not point to evidence raising a genuine dispute for any of 22 these claims. Therefore I grant Albertson’s motion for summary judgment on Guido’s negligent 23 hiring, training, supervision, and retention claims. 1 B. Premises Liability Negligence (Count 1) 2 Albertson’s argues that Guido failed to produce any evidence to demonstrate that it had 3 actual or constructive notice of the water on the floor. Guido responds that Albertson’s either 4 had constructive knowledge of the spill because of the prevalence of water dripping in the floral

5 department or that Albertson’s caused the spill by using a leaky water bucket in the floral 6 display. 7 “A business owes its patrons a duty to keep the premises in a reasonably safe condition 8 for use.” FGA, Inc. v. Giglio, 278 P.3d 490, 496 (Nev. 2012) (simplified). Although Albertson’s 9 is not automatically liable for an accident occurring on its premises, Guido may establish liability 10 either (1) by proving that Albertson’s or its employees caused the water to be on the floor, or 11 (2) by proving that Albertson’s had actual or constructive notice of the condition and failed to 12 remedy it. Sprague v. Lucky Stores, Inc., 849 P.2d 320, 322-23 (Nev. 1993). Whether the 13 business had constructive notice of the hazardous condition is generally “a question of fact 14 properly left for the jury.” Id. at 323.

15 Viewing the evidence in the light most favorable to Guido, a reasonable jury could 16 conclude that Albertson’s breached its duty. The Albertson’s Rule 30(b)(6) witness testified that 17 customers do not always place flowers in plastic bags when they remove the flowers from the 18 water buckets, causing water to drip on the floor. ECF No. 23-1 at 34-35. Albertsons has some 19 carpeted mats in the floral area, but they do not completely surround the floral displays. Id. at 42- 20 43; ECF No. 23-4. The parties also dispute when the most recent sweep of the area was 21 completed or whether the sweeper covered the floral department, and the excerpted video exhibit 22 does not show a sweeper during the 20-minute period covered in the exhibit. ECF Nos. 23-1 at 23 35-40; 24. After Guido’s fall, an Albertson’s floral employee is seen on the video twice 1 removing empty water buckets from the area of the fall, which may support an inference that one 2 or both were leaking, particularly because the employee places one bucket atop a stack of 3 buckets but places the other bucket in a separate location. ECF No. 24 at 15:25, 19:15.1 4 Additionally, as discussed below, Albertson’s either did not create or did not preserve its

5 customer/vendor worksheet that would have contained its investigative findings as to the source 6 of the water on the ground. A reasonable jury could infer that Albertson’s lost or destroyed this 7 evidence because it was unfavorable to Albertson’s. I therefore deny Albertson’s motion for 8 summary judgment as to Guido’s premises liability negligence claim. 9 C. Spoliation 10 Guido moves for sanctions, contending that Albertson’s lost or destroyed its 11 customer/vendor worksheet even though Albertson’s was on notice that Guido was injured in her 12 fall.2 She requests sanctions either establishing conclusively that Albertson’s had notice of the 13 hazard or by issuing an adverse presumption as to both liability and damages. Albertson’s 14 argues that there is not sufficient evidence to show that the document ever existed or that it

15 would have been useful to Guido, so sanctions are not warranted.

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Related

Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
In Re Oracle Corp. Securities Litigation
627 F.3d 376 (Ninth Circuit, 2010)
Sprague v. Lucky Stores, Inc.
849 P.2d 320 (Nevada Supreme Court, 1993)
FGA, INC. v. Giglio
278 P.3d 490 (Nevada Supreme Court, 2012)
Victoria Ryan v. Editions Limited West, Inc.
786 F.3d 754 (Ninth Circuit, 2015)
Victoria Zetwick v. County of Yolo
850 F.3d 436 (Ninth Circuit, 2017)
United States v. Kitsap Physicians Service
314 F.3d 995 (Ninth Circuit, 2002)
Sonner v. Schwabe N. Am., Inc.
911 F.3d 989 (Ninth Circuit, 2018)
Carrie Gregory v. State of Montana
118 F.4th 1069 (Ninth Circuit, 2024)

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Bluebook (online)
Del Carmen Guido v. Albertson's LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/del-carmen-guido-v-albertsons-llc-nvd-2024.