Lynette Washington v. Minute Mart, Inc. D/B/A Breaux's Mart

CourtLouisiana Court of Appeal
DecidedOctober 19, 2022
DocketCW-0022-0119
StatusUnknown

This text of Lynette Washington v. Minute Mart, Inc. D/B/A Breaux's Mart (Lynette Washington v. Minute Mart, Inc. D/B/A Breaux's Mart) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lynette Washington v. Minute Mart, Inc. D/B/A Breaux's Mart, (La. Ct. App. 2022).

Opinion

NOT DESIGNATED FOR PUBLICATION

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

22-119

LYNETTE WASHINGTON

VERSUS

MINUTE MART, INC.

D/B/A BREAUX’S MART

**********

APPEAL FROM THE FIFTEENTH JUDICIAL DISTRICT COURT PARISH OF LAFAYETTE, NO. 2019 7797 B HONORABLE VALERIE C. GOTCH GARRETT, DISTRICT JUDGE

ELIZABETH A. PICKETT JUDGE

Court composed of Elizabeth A. Pickett, Billy Howard Ezell, and Shannon J. Gremillion, Judges.

WRIT GRANTED AND MADE PEREMPTORY; JUDGMENT OF TRIAL COURT REVERSED AND RENDERED.

Bonita K. Preuett-Armour Armour Law Firm P. O. Box 8386 Alexandria, LA 71306 (318) 442-6611 COUNSEL FOR DEFENDANT-APPLICANT: Minute Mart, Inc. d/b/a Breaux’s Mart David D. Benoit Justin R. Cantu P. O. Box 877 Breaux Bridge, LA 70517 (337) 332-6666 COUNSEL FOR PLAINTIFF-RESPONDENT: Lynette Washington PICKETT, Judge.

The defendant-relator, Minute Mart, Inc. d/b/a Breaux’s Mart, (Minute Mart)

seeks supervisory writs from the judgment of the trial court which denied Minute

Mart’s motion for summary judgment.

FACTS

As Lynette Martin entered Breaux’s Mart on October 14, 2019, she alleges

she tripped over a floormat and fell, breaking her collarbone. In her petition

against Minute Mart, she alleges the floormat was “wadded up” which caused her

to stumble over it. She filed her Petition for Damages on December 17, 2019,

naming Minute Mart as defendant.

On June 29, 2021, Minute Mart filed a Motion for Summary Judgment,

asserting that there was an absence of factual support for the elements essential to

Washington’s cause of action and that Washington would be unable to produce

factual support sufficient to establish the existence of a genuine issue of material

fact. A hearing on the motion was held on September 10, 2021, and the matter was

taken under advisement. On November 24, 2021, the trial court issued Written

Reasons for Judgment, concluding that “there are genuine issues of material fact

beyond the mere allegations or denials of the pleadings.” A written Judgment on

Motion for Summary Judgment was signed on January 5, 2022. Minute Mart filed

an application for supervisory writs in this court seeking review of the trial court’s

ruling. We granted the writ on May 4, 2022, and issued an order allowing the

parties to file additional briefs and request oral argument. See La.Code Civ.P. art.

966(H). Minute Mart timely requested oral argument, which this court granted. ASSIGNMENT OF ERROR

Minute Mart asserts one assignment of error:

The trial court erred in denying Breaux’s Mart’s Motion for Summary Judgment where Breaux’s Mart pointed out the absence of factual support for one or more elements essential to Ms. Washington’s claim and where Ms. Washington failed to produce factual support sufficient to establish the existence of a genuine issue of material fact or that Breaux’s Mart is not entitled to judgment as a matter of law.

DISCUSSION

Since the denial of a motion for summary judgment is an interlocutory ruling

from which no appeal may be taken, the only practical remedy available to avoid a

possible useless trial on the merits is to request that the appellate court exercise its

supervisory jurisdiction to review the propriety of this ruling. Louviere v. Byers,

526 So.2d 1253 (La. App. 3 Cir.), writ denied, 528 So.2d 153 (La.1988).

On a motion for summary judgment, the burden of proof remains with the mover. However, if the moving party will not bear the burden of proof on the issue at trial and points out an absence of factual support for one or more elements essential to the adverse party’s claim, action, or defense, then the non-moving party must produce factual support sufficient to establish that he will be able to satisfy his evidentiary burden of proof at trial. If the opponent of the motion fails to do so, there is no genuine issue of material fact and summary judgment will be granted. La. Code Civ. P. art. 966(D)(1); Stephenson v. Bryce W. Hotard Sunbelt Rentals, Inc., 2019-0478 (La. 5/20/19), 271 So.3d 190, 193; Bufkin v. Felipe’s Louisiana, LLC, 2014-0288 (La. 10/15/14), 171 So.3d 851, 854; Schultz v. Guoth, 2010-0343 (La. 1/19/11), 57 So.3d 1002, 1006.

Planchard v. New Hotel Monteleone, LLC, 21-347, p. 3 (La. 12/10/21), 332 So.3d

623, 625.

Minute Mart directs this court to the statute which governs merchant

liability, La.R.S. 9:2800.6, which reads as follows:

A. A merchant owes a duty to persons who use his premises to exercise reasonable care to keep his aisles, passageways, and floors in a reasonably safe condition. This duty includes a reasonable effort to keep the premises free of any hazardous conditions which reasonably might give rise to damage.

2 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.

C. Definitions:

(1) “Constructive notice” means the claimant has proven that the condition existed for such a period of time that it would have been discovered if the merchant had exercised reasonable care. The presence of an employee of the merchant in the vicinity in which the condition exists does not, alone, constitute constructive notice, unless it is shown that the employee knew, or in the exercise of reasonable care should have known, of the condition.

(2) “Merchant” means one whose business is to sell goods, foods, wares, or merchandise at a fixed place of business. For purposes of this Section, a merchant includes an innkeeper with respect to those areas or aspects of the premises which are similar to those of a merchant, including but not limited to shops, restaurants, and lobby areas of or within the hotel, motel, or inn.

D. Nothing herein shall affect any liability which a merchant may have under Civil Code Arts. 660, 667, 669, 2317, 2322, or 2695.

Minute Mart correctly asserts that a plaintiff must prove each of the three elements

set forth in La.R.S. 9:2800.6(B). Failure to prove any of these elements is fatal to a

plaintiff’s claim. White v. Wal–Mart Stores, Inc., 97-393 (La. 9/9/97), 699 So.2d

1081. Minute Mart contends that there is an absence of factual support for each of 3 these elements and that Plaintiff has not produced factual support sufficient to

establish the existence of a genuine issue of material fact.

Minute Mart first argues that the condition of the mat did not present an

unreasonable risk of harm. La.R.S. 9:2800.6(B)(1). Minute Mart points out that

Washington is not claiming that the presence of the mat or the mat itself is

defective. Instead, Washington claims that the mat presented an unreasonable risk

of harm due to a “wedge” in the mat. Washington testified, however, that she did

not see the wedge until after she had fallen and gotten back up and she did not

know whether her fall caused the wedge to occur.

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Lynette Washington v. Minute Mart, Inc. D/B/A Breaux's Mart, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lynette-washington-v-minute-mart-inc-dba-breauxs-mart-lactapp-2022.