Jordan Curtis v. Price Holdings, Inc. D/B/A Franklin Drive-In

CourtCourt of Appeals of Kentucky
DecidedSeptember 3, 2020
Docket2018 CA 001777
StatusUnknown

This text of Jordan Curtis v. Price Holdings, Inc. D/B/A Franklin Drive-In (Jordan Curtis v. Price Holdings, Inc. D/B/A Franklin Drive-In) is published on Counsel Stack Legal Research, covering Court of Appeals of Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jordan Curtis v. Price Holdings, Inc. D/B/A Franklin Drive-In, (Ky. Ct. App. 2020).

Opinion

RENDERED: SEPTEMBER 4, 2020; 10:00 A.M. TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

NO. 2018-CA-001777-MR

JORDAN CURTIS APPELLANT

APPEAL FROM SIMPSON CIRCUIT COURT v. HONORABLE JANET J. CROCKER, JUDGE ACTION NO. 17-CI-00049

PRICE HOLDINGS, INC. d/b/a FRANKLIN DRIVE-IN APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: ACREE, COMBS, AND MAZE, JUDGES.

ACREE, JUDGE: The Simpson Circuit Court entered a final judgment upon jury

verdict in favor of appellee, Price Holdings, Inc. d/b/a Franklin Drive-In (Price).

Appellant, Jordan Curtis, brings this appeal claiming the circuit court erred by

excluding evidence of subsequent remedial measures and by failing to give a

missing evidence instruction. After careful review, we affirm. BACKGROUND AND PROCEDURAL HISTORY

Shortly before October 2016, Price bought 80 tons of asphalt to

repave areas near the concession stand at the Franklin Drive-In outdoor theater.

(Gary Price Depo., pp. 12-15). The events giving rise to this action occurred

before that delivery and repaving could happen.

On October 1, 2016, Curtis was attending the drive-in with family and

friends. Near the end of the first movie, Curtis’s three-year-old daughter needed to

use the bathroom at the concession stand. Curtis carried her to and from the

restroom. On her return, Curtis fell.1 She sustained a distal fibial fracture

requiring surgery and was taken away by ambulance. Gary Price, co-owner of

Price Holdings, was operating the drive-in that night, though he did not see the fall

or learn that night the specific location of the fall.

A few days later, Curtis sent Price a Facebook message, seeking his

insurance information. Price provided the information, informed his insurer of the

accident and, at the insurer’s request, took several photographs of the “general

area” where Curtis fell.2 Curtis’s attorney or her attorney’s representative also

visited the drive-in and took photos of the “general area” of the accident.

1 The concession/restroom is located on asphalt. Adjacent to this asphalt area is a gravel area, where the Curtis vehicle was parked. It is not refuted that she fell in the vicinity where asphalt meets gravel. 2 One of the evidentiary obstacles that had to be maneuvered was avoidance of disclosure that the photos were taken for insurance purposes. Finch v. Conley, 422 S.W.2d 128, 130 (Ky. 1967)

-2- On October 12, Curtis’s attorney sent Price a spoliation letter, stating:

In order to represent Jordan Curtis to the best of our ability, we must secure all potential evidence. At this time, we would like to request you to secure the video footage involved in this incident and make it available for our expert to inspect.[3] Please contact our office to make arrangements for this inspection.

Do not alter the evidence in any way until we have had an opportunity to do our inspection. Failure to comply would be considered spoliation of evidence and could result in penalties assigned by the court.

If your insurance company has possession of the evidence, please forward a copy of this letter to them immediately. We will deal with them directly.

(Record (R.) at 116).

The 80 tons of asphalt were delivered in early November and the area

around the concession stand was paved, including where Curtis fell.

Curtis filed a tort action against Price alleging negligence and

premises liability. Soon, Curtis filed a motion for summary judgment as to Price’s

liability or, in the alternative, for a missing evidence instruction on the basis that

Price destroyed evidence of the uneven or broken asphalt. The circuit court denied

(“[R]eference to . . . insurance . . . except in the absence of a clear showing of non-prejudice, will constitute a reversible error.” (Citation and internal quotation marks omitted)). 3 Price acknowledged that he received the letter, but the video footage automatically had been recorded over several days before the spoliation letter was written.

-3- summary judgment and reserved ruling on a missing evidence instruction pending

presentation of evidence.

However, the court granted Price’s motion to exclude evidence of the

subsequent remedial measure but did so only provisionally. The circuit court’s

order stated, in pertinent part, as follows:

[E]vidence of Price’s subsequent remedial measures is inadmissible so long as Price does not assert that Curtis is unable to identify the location where she fell. However, if Price “opens the door,” then Curtis will be allowed to impeach his testimony with proof that Price paved the area in and around the location of her accident.

(Order, entered October 5, 2018, R. at 376).

At trial, Curtis sought to question Gary Price on this subsequent

remedial measure, contending Price had opened the door to this line of questioning

by his testimony denying the existence of any dangerous conditions, “and that the

property was as safe as it could be[.]” (Appellant’s brief, p. 11). Curtis wanted to

present evidence of the subsequent repairs to impeach that statement. The circuit

court would not allow that line of questioning.

The jury returned a verdict for Price. This appeal followed. Other

facts will be provided as necessary in the context of the analysis.

-4- ANALYSIS

Curtis argues the circuit court erred in two ways: (1) by excluding

evidence of Price’s subsequent repairs; and (2) by failing to give a missing

evidence jury instruction. We are not persuaded by either argument.

We review a circuit court’s evidentiary ruling for an abuse of

discretion. Benjamin v. Commonwealth, 266 S.W.3d 775, 791 (Ky. 2008).

Likewise, “[i]t is within the trial court’s discretion to deny a requested instruction,

and its decision will not be reversed absent an abuse of discretion.” Auslander

Properties, LLC v. Nalley, 558 S.W.3d 457, 469 (Ky. 2018) (citing Olfice, Inc. v.

Wilkey, 173 S.W.3d 226, 229 (Ky. 2005)). “The test for abuse of discretion is

whether the trial judge’s decision was arbitrary, unreasonable, unfair, or

unsupported by sound legal principles.” Commonwealth v. English, 993 S.W.2d

941, 945 (Ky. 1999) (citations omitted).

Subsequent Remedial Measures

The admissibility of evidence of subsequent remedial measures is

governed by KRE4 407. That Rule says:

When, after an event, measures are taken which, if taken previously, would have made an injury or harm allegedly caused by the event less likely to occur, evidence of the subsequent measures is not admissible to prove negligence, culpable conduct, a defect in a product, a defect in a product’s design, or a need for a warning or

4 Kentucky Rules of Evidence.

-5- instruction. This rule does not require the exclusion of evidence of subsequent measures when offered for another purpose, such as proving ownership, control, or feasibility of precautionary measures, if controverted, or impeachment.

KRE 407 (emphasis added).

Curtis argues that the last two exceptions to KRE 407 apply. First,

she contends Price controverted the feasibility of precautionary measures and that

proof of subsequent remedial repairs should have been allowed to refute that

testimony.

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Related

Olfice, Inc. v. Wilkey
173 S.W.3d 226 (Kentucky Supreme Court, 2005)
Davis v. Fischer Single Family Homes, Ltd.
231 S.W.3d 767 (Court of Appeals of Kentucky, 2007)
Benjamin v. Commonwealth
266 S.W.3d 775 (Kentucky Supreme Court, 2008)
Commonwealth v. English
993 S.W.2d 941 (Kentucky Supreme Court, 1999)
Finch v. Conley
422 S.W.2d 128 (Court of Appeals of Kentucky, 1967)
University Medical Center, Inc. v. Beglin
375 S.W.3d 783 (Kentucky Supreme Court, 2011)
Auslander Props., LLC v. Nalley
558 S.W.3d 457 (Missouri Court of Appeals, 2018)

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Jordan Curtis v. Price Holdings, Inc. D/B/A Franklin Drive-In, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jordan-curtis-v-price-holdings-inc-dba-franklin-drive-in-kyctapp-2020.