Hou v. P N K Lake Charles L L C

CourtDistrict Court, W.D. Louisiana
DecidedJuly 8, 2025
Docket2:24-cv-00954
StatusUnknown

This text of Hou v. P N K Lake Charles L L C (Hou v. P N K Lake Charles L L C) is published on Counsel Stack Legal Research, covering District Court, W.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hou v. P N K Lake Charles L L C, (W.D. La. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF LOUISIANA LAKE CHARLES DIVISION

CHHENG LEANG HOU CASE NO. 2:24-CV-00954

VERSUS JUDGE JAMES D. CAIN, JR.

P N K LAKE CHARLES L L C MAGISTRATE JUDGE DAVID J. AYO

MEMORANDUM RULING Before the Court is a “Motion for Summary Judgment” (Doc. 15) filed by Defendant, PNK (Lake Charles) LLC, (“PNK”) who is moving to dismiss this lawsuit. BACKGROUND PNK operates the L’Auberge Casino Resort in Lake Charles, Louisiana.1 Chheng Leang Hou and her family were staying in the hotel on the night of the incident. On November 22, 2023, Chheng Leang Hou was walking out of the elevators into the hallway of L’Auberge when she fell.2 Ms. Hou alleges that she suffered a bone fracture to her right leg because of the fall. Video surveillance recorded the fall.3 The video surveillance shows Ms. Hou, her son, her 5 or 6-year-old grandson, and her son’s girlfriend, who was pushing the baby carriage take an elevator to the casino floor.4 As the group left the elevator, they turned and

1 Declaration of Gerald Forester, Exhibit D-1, ¶ 2. 2 Id. 3 Declaration of Laura Duplechain, Exhibit D-3, ¶ 12 with reference to jump drive submitted as manual filing. 4 Id.; Hou depo., P. 9, ln. 22-P. 11 ln. 18; P. 19 ln. 15-16 and depo Exhibit 2; Duplechain declaration ¶ 10 and video See video labeled “7003 Elevator P4” walked down the elevator hall headed to the restaurant and casino area.5 While walking to the casino area, they walked toward an open doorway where the doors were opened towards them.6 As Ms. Hou and her family walked through the elevator hallway, her grandson

began jumping and running.7 At 19:26:53 Ms. Hou grabbed her grandson’s right arm or hand with her left hand.8 At 19:26:54, the child was running with Ms. Hou holding onto his hand.9 At 19:26:55, the boy’s arm was stretched behind him and Ms. Hou’s arm was extended toward him with her head facing downward.10 At the time, Ms. Hou was approaching the edge of the door furthest into the hallway. Ms. Hou’s grandson started

pulling her to the left.11 Ms. Hou is seen with her body projected forward.12 Video labeled “416-Slot Section 1” shows the grandson fall and Ms. Hou fall on top of him.13 At 19:26:56, Ms. Hou’s grandson is seen falling forward with his head beside the door.14 His feet had not reached the floor joint when he fell.15 At 19:26:57, Ms. Hou is seen next to the open door as she was falling on top of her grandson.16

SUMMARY JUDGMENT STANDARD

A court should grant a motion for summary judgment when the movant shows “that there is no genuine dispute as to any material fact and the movant is entitled to judgment

5 Id. ¶ 10 6 Id. ¶ 11 and video labeled “7011 Elevator L1 P Lobby” 7 Hou Depo., P. 33, Lns. 15-24 8 Duplechain declaration ¶ 11 9 Id. ¶ 13 10 Id. ¶ 13 11 Id. Hou Depo., P. 34, Lns. 4-8 12 Id.; Hou Depo., P. 34, Lns. 18-23, P. 35, Lns. 14-18 13 Duplechain declaration ¶ 13 14 Id. 15 Hou Depo. P. 40, Lns. 8-20; Duplechain declaration ¶ 12 16 Hou Depo. as a matter of law.” FED. R. CIV. P. 56. The party moving for summary judgment is initially responsible for identifying portions of pleadings and discovery that show the lack of a

genuine issue of material fact. Tubacex, Inc. v. M/V Risan, 45 F.3d 951, 954 (5th Cir. 1995). The court must deny the motion for summary judgment if the movant fails to meet this burden. Id. If the movant makes this showing, however, the burden then shifts to the non- moving party to “set forth specific facts showing that there is a genuine issue for trial.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986) (quotations omitted). This

requires more than mere allegations or denials of the adverse party's pleadings. Instead, the nonmovant must submit “significant probative evidence” in support of his claim. State Farm Life Ins. Co. v. Gutterman, 896 F.2d 116, 118 (5th Cir. 1990). “If the evidence is merely colorable, or is not significantly probative, summary judgment may be granted.” Anderson, 477 U.S. at 249 (citations omitted).

A court may not make credibility determinations or weigh the evidence in ruling on a motion for summary judgment. Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133, 150 (2000). The court is also required to view all evidence in the light most favorable to the non-moving party and draw all reasonable inferences in that party’s favor. Clift v. Clift, 210 F.3d 268, 270 (5th Cir. 2000). Under this standard, a genuine issue of material

fact exists if a reasonable trier of fact could render a verdict for the nonmoving party. Brumfield v. Hollins, 551 F.3d 322, 326 (5th Cir. 2008). LAW AND ANALYSIS Under Erie Railroad Co. v. Tompkins, 304 U.S. 64 (1938), a federal court sitting in

diversity jurisdiction applies the substantive law of the forum state. E.g., Cates v. Sears, Roebuck & Co., 928 F.2d 679, 687 (5th Cir. 1991). In Louisiana, claims against merchants based on falls on the premises are governed by the Louisiana Merchant Liability Act (“LMLA”), Louisiana Revised Statute § 9:2800.6. To prove liability against a merchant, plaintiff, who is alleging a trip and fall injury sustained on such merchant’s premises, has the burden of proving those elements set forth

in Louisiana Revised Statute 9:2880.6. Section B thereof provides that: B. In a negligence claim brought against a merchant by a person lawfully on the merchant’s premises for damages as a result of an injury, death, or loss sustained because of a fall due to a condition existing in or on a merchant’s premises, the claimant shall have the burden of proving, in addition to all other elements of his cause of action, all of the following:

(1) The condition presented an unreasonable risk of harm to the claimant and that risk of harm was reasonably foreseeable.

(2) The merchant either created or had actual or constructive notice of the condition which caused the damage, prior to the occurrence.

(3) The merchant failed to exercise reasonable care. In determining reasonable care, the absence of a written or verbal uniform cleanup or safety procedure is insufficient, alone, to prove failure to exercise reasonable care.

A plaintiff must prove each of the above three elements. Failure to prove any element will defeat a plaintiff’s claim. White v. Walmart Stores, Inc., 699 So.2d 1081 (La. 9/9/97). Although the merchant has an affirmative duty to keep the premises in a safe condition, a merchant is not the insurer of the safety of his patrons. Jackson-Silvan v. State Farm Cas. Ins. Co., 171 So.3d 252 (La. App. 3 Cir. 2011) writ denied, (La. 5/22/15). Unreasonably dangerous

In determining whether a condition is unreasonably dangerous, Louisiana courts apply the risk/utility balancing test, which considers the following factors: (1) the utility of the complained-of condition; (2) the likelihood and magnitude of harm, including the obviousness and apparentness of the condition; (3) the cost of preventing the harm; and (4) the nature of the plaintiff’s activities in terms of social utility or whether the activities were

dangerous by nature. Farrell v. Circle K Stores, Inc., 359 So.3d 467 (La. 3/17/2023).

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Related

Tubacex, Inc. v. M/V Risan
45 F.3d 951 (Fifth Circuit, 1995)
Brumfield v. Hollins
551 F.3d 322 (Fifth Circuit, 2008)
Erie Railroad v. Tompkins
304 U.S. 64 (Supreme Court, 1938)
Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Reeves v. Sanderson Plumbing Products, Inc.
530 U.S. 133 (Supreme Court, 2000)
White v. Wal-Mart Stores, Inc.
699 So. 2d 1081 (Supreme Court of Louisiana, 1997)

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Hou v. P N K Lake Charles L L C, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hou-v-p-n-k-lake-charles-l-l-c-lawd-2025.