KAREN ALLEN VS. FAMILY MEDICAL EQUIPMENT (L-0552-17, CUMBERLAND COUNTY AND STATEWIDE)

CourtNew Jersey Superior Court Appellate Division
DecidedNovember 10, 2021
DocketA-3562-19
StatusUnpublished

This text of KAREN ALLEN VS. FAMILY MEDICAL EQUIPMENT (L-0552-17, CUMBERLAND COUNTY AND STATEWIDE) (KAREN ALLEN VS. FAMILY MEDICAL EQUIPMENT (L-0552-17, CUMBERLAND COUNTY AND STATEWIDE)) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
KAREN ALLEN VS. FAMILY MEDICAL EQUIPMENT (L-0552-17, CUMBERLAND COUNTY AND STATEWIDE), (N.J. Ct. App. 2021).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited. R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-3562-19

KAREN ALLEN and JAMES ALLEN,

Plaintiffs-Appellants,

v.

FAMILY MEDICAL EQUIPMENT,

Defendant-Respondent,

and

MEDICAL DEPOT INCORPORATED,

Defendant. __________________________

Argued October 4, 2021 – Decided November 10, 2021

Before Judges Sabatino, Rothstadt, and Natali.

On appeal from the Superior Court of New Jersey, Law Division, Cumberland County, Docket No. L-0552-17. Matthew Weng argued the cause for appellant (Chance & McCann, LLC, attorneys; Matthew Weng, on the briefs).

Dennis M. Marconi argued the cause for respondent (Barnaba & Marconi, LLP, attorneys; Dennis Marconi, on the brief).

PER CURIAM

In this personal injury action, plaintiffs Karen and James Allen appeal

from an April 24, 2020 order awarding defendant Family Medical Equipment

summary judgment and dismissing plaintiffs' complaint. The complaint sought

damages for injuries Karen 1 sustained in a fall that occurred as she attempted to

stand up from a raised toilet seat with arm rests, which she used immediately

after defendant's employee delivered and installed at plaintiffs' home.2 In their

complaint, plaintiffs alleged defendant was "negligent in [its] choice, instruction

for use given to plaintiffs, or installation of the raised toilet seat." In opposition

to a summary judgment motion filed by defendant, plaintiffs did not support

1 Plaintiffs are married. We refer to them individually by their first names to avoid any confusion caused by their common last name. 2 The product was manufactured by defendant Medical Depot. The summary judgment orders entered in this case also dismissed plaintiffs' defective product claim against Medical Depot. However, after plaintiffs filed their appeal from both orders, plaintiffs and Medical Depot filed a Stipulation of Dismissal with prejudice on December 17, 2020, as to plaintiffs' claims against Medical Depot.

A-3562-19 2 their claim with any expert opinions or other direct evidence of defendant's

negligence, but instead relied upon the doctrine of res ipsa loquitur.3 The motion

judge disagreed with plaintiffs that the doctrine applied and entered the order

dismissing their complaint.

We affirm, as we conclude from our de novo review of her order, the

motion judge correctly determined res ipsa loquitur did not apply to plaintiffs'

claims, but we reach this conclusion for a slightly different reason.

The material facts viewed in the light most favorable to plaintiffs are not

generally in dispute and are summarized as follows. Prior to her fall, in July

2015, Karen suffered a stroke that led to her hospitalization and admission to a

rehabilitation facility. As a result of her stroke, she was "weak on the left side"

and could not stand up from a seated position without the assistance of her

husband or a cane. As part of her discharge, the rehabilitation facility issued an

order for Karen to have a raised toilet seat installed at her home.

Shortly after her release, Karen returned home and ordered the raised

toilet seat from defendant. The item was delivered to plaintiffs' house on August

5, 2015, by one of defendant's employees, who installed the product in plaintiffs'

3 As discussed in more detail infra, the doctrine permits proof of negligence by inference under limited circumstances. A-3562-19 3 bathroom while they observed his actions. According to Karen, the employee

brought the box containing the raised toilet seat to the bathroom and "screwed

[the toilet seat] down" "against the toilet," which took five minutes to complete.

The employee did not speak to plaintiffs, he never showed plaintiffs how to sit

on the raised toilet seat, and he did not ask either plaintiff to attempt to sit on

the product before he left the house, and plaintiffs did not request that he observe

either of them sitting down and standing up from it before he departed.

The employee did have James sign a delivery ticket, acknowledging

delivery and that plaintiffs' received written instructions about the product's

use.4 The document included an acknowledgment that

[a]ll Manufacturer environmental and safety checks have been performed per Company Policy prior to delivery and reviewed with the patient upon delivery including[:] Safe use of the equipment in your home setting. All risk of potential harm from use of the above equipment have been reviewed and safe storage and maintenance requirements including cleaning and regular safety checks have been reviewed with me. Written instructions and Warranty information have been given to me reinforcing this content.

[(Emphasis added).]

4 The document appears in the record to bear James' signature, but at her deposition, Karen stated she signed the document. A-3562-19 4 Instructions about the product's installation and use were typically located

in the product's box, which the employee left at plaintiffs' home. The

instructions indicated, among other things, that the "[u]ser's weight should be

centered over toilet seat, not too far forward or too far to one side, as unit may

tip." Additionally, the instruction manual included a "CAUTION" section with

the following warnings:

1. Always be sure that the seat is correctly and securely locked in place before using. 2. Be sure that the adjustment knob in front of the seat is tight at all times, thus securing the seat to the toilet bowl. 3. . . . [B]e sure that the unit is correctly installed, fits properly and is stable before use. 4. On models with arm rests: The arms are for the purpose of providing assistance when getting on and off the seat. DO NOT try to use the arms to support full body weight during transfer, as this may result in failure of the unit.

Although Karen stated she read the signed acknowledgement confirming

receipt of the instructions, she never read any instructions about how to attach

or use the raised toilet seat, and she did not speak with anyone about them.

According to plaintiffs, when the employee left, the raised toilet seat

seemed to be tight on the toilet and sturdy. James confirmed he saw defendant's

employee tightened the knob on the raised toilet seat and then "checked" the

A-3562-19 5 toilet seat by putting his hands on the handles and "rock[ing] it a little bit " to

"see if it was tight." According to James, the seat "seemed to be" tight after he

witnessed this check by the employee. Plaintiffs did not test the raised toilet

seat before Karen used it for the first time after the employee left. When she

did, she fell off it and sustained injuries.

Karen described how she used the toilet seat as having "[g]rabbed the side

– each of the rails, went to stand up. When I went to stand up, the thing went

off the toilet and I went on the floor with it." She also described the incident as

occurring after she "sat down. When I got ready to get up, the whole thing come

off, and me and that went on the floor." According to Karen, her husband

assisted her when she first sat down, but she did not call him for help when she

was ready to stand up.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Jimenez v. GNOC, CORP.
670 A.2d 24 (New Jersey Superior Court App Division, 1996)
Saks v. Ng
890 A.2d 983 (New Jersey Superior Court App Division, 2006)
Buckelew v. Grossbard
435 A.2d 1150 (Supreme Court of New Jersey, 1981)
Szalontai v. Yazbo's Sports Café
874 A.2d 507 (Supreme Court of New Jersey, 2005)
Hoffman v. Asseenontv. Com, Inc.
962 A.2d 532 (New Jersey Superior Court App Division, 2009)
Manalapan Realty v. Township Committee of the Township of Manalapan
658 A.2d 1230 (Supreme Court of New Jersey, 1995)
Myrlak v. Port Auth. of NY and NJ
723 A.2d 45 (Supreme Court of New Jersey, 1999)
Jerista v. Murray
883 A.2d 350 (Supreme Court of New Jersey, 2005)
Brown v. Racquet Club of Bricktown
471 A.2d 25 (Supreme Court of New Jersey, 1984)
Brill v. Guardian Life Insurance Co. of America
666 A.2d 146 (Supreme Court of New Jersey, 1995)
Anderson v. Somberg
338 A.2d 1 (Supreme Court of New Jersey, 1975)
Petersen v. TOWNSHIP OF RARITAN
12 A.3d 250 (New Jersey Superior Court App Division, 2011)
Deborah Townsend v. Noah Pierre (072357)
110 A.3d 52 (Supreme Court of New Jersey, 2015)
Kazala v. Prudential Insurance Co. of America
95 A.2d 747 (Supreme Court of New Jersey, 1953)
Luciano v. Port Authority Trans-Hudson Corp.
703 A.2d 690 (New Jersey Superior Court App Division, 1997)
Roper v. Blumenfeld
706 A.2d 1151 (New Jersey Superior Court App Division, 1998)
Heyert v. Taddese
70 A.3d 680 (New Jersey Superior Court App Division, 2013)
Town of Kearny v. Brandt
67 A.3d 601 (Supreme Court of New Jersey, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
KAREN ALLEN VS. FAMILY MEDICAL EQUIPMENT (L-0552-17, CUMBERLAND COUNTY AND STATEWIDE), Counsel Stack Legal Research, https://law.counselstack.com/opinion/karen-allen-vs-family-medical-equipment-l-0552-17-cumberland-county-and-njsuperctappdiv-2021.