Mario Olga Garcia v. Sellers Bros. Inc.

CourtCourt of Appeals of Texas
DecidedNovember 21, 2006
Docket14-05-00954-CV
StatusPublished

This text of Mario Olga Garcia v. Sellers Bros. Inc. (Mario Olga Garcia v. Sellers Bros. Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mario Olga Garcia v. Sellers Bros. Inc., (Tex. Ct. App. 2006).

Opinion

Affirmed and Memorandum Opinion filed November 21, 2006

Affirmed and Memorandum Opinion filed November 21, 2006.

In The

Fourteenth Court of Appeals

____________

NO. 14-05-00954-CV

MARIA OLGA GARCIA, Appellant

V.

SELLERS BROS., INC., Appellee

On Appeal from the 215th District Court

Harris County, Texas

Trial Court Cause No. 04-36818

M E M O R A N D U M   O P I N I O N

In this premises liability case, appellant Maria Olga Garcia appeals the summary judgment granted in favor of appellee Sellers Bros., Inc., the owner of a food store where Garcia claimed she was injured when she slipped and fell in a puddle of liquid.  Garcia contends she raised genuine issues of material fact on the elements of her premises liability claim, and further contends that the trial court erred in disregarding her evidence of spoliation.  We affirm.

Factual and Procedural Background

Shortly after noon on April 27, 2004, while inside a retail food store owned by Sellers, Garcia slipped in a large puddle of a liquid cleaner she identified as APine-O-Pine.@  When Garcia fell, her pants, shoes and shirt became wet with the liquid.  A few feet away, a container of a liquid cleaner identified by Sellers as APinalen@ was discovered on top of some boxes of liquid soap.  The 33-ounce container was about half full and broken on the bottom.  According to Garcia, she saw the container Aleaking from the boxes.@  As a result of the accident, Garcia suffered pain in her left shoulder.

In July 2005, Garcia sued Sellers for premises liability.  After Garcia filed her second amended petition, Sellers moved for a no-evidence summary judgment.  Garcia then amended her petition a third time to include an allegation of spoliation of evidence because Sellers did not retain the container of liquid cleaner. 

After Garcia filed her third amended petition, Sellers amended its motion for summary judgment to assert both a no-evidence and a traditional motion for summary judgment.  Garcia then filed a fourth amended petition as well as a response to Sellers= amended motion for summary judgment.  In the response, Garcia asserted an additional basis for spoliation of evidence: she claimed that, shortly after the incident, Sellers either knowingly or negligently removed a videotape from surveillance cameras in the area where she fell.

In its reply to Garcia=s response to its amended motion for summary judgment, Sellers addressed both the substantive claims and the spoliation claim based on Sellers= alleged failure to retain the container; however, Sellers did not respond to the claim concerning the videotape.  In Garcia=s fifth amended petition, filed July 14, 2005, she added the same allegations she made in response to Sellers= amended motion for summary judgment of spoliation based on both the container and the videotape. 

On August 10, 2005, the trial court signed an order granting Sellers= first amended motion for summary judgment.  The trial court=s order stated in relevant part:

The Court noted that after the defendant filed its first amended motion, the plaintiff filed her fifth amended original petition.  The fifth amended original petition adds a claim of spoliation of evidence.  The plaintiff asks for Aall relief allowed for under the Rules regarding the defendant=s spoliation of evidence, including but not limited to an appropriate instruction to the jury.@  . . . The Court hereby disposes of the spoliation claim finding that no relief is available as a matter of law in light of the fact that the Court finds the defendant is entitled to judgment as a matter of law on plaintiff=s premises claim.

This appeal followed.

Analysis of Garcia=s Issues

Below, Sellers claimed it was entitled to summary judgment because Garcia had no evidence that (1) Sellers had actual or constructive knowledge of the condition on its premises, (2) Sellers failed to exercise reasonable care to reduce or eliminate the risk; and (3) its failure of care proximately caused Garcia=s injury.  See CMH Homes, Inc. v. Daenen, 15 S.W.3d 97, 99 (Tex. 2000).[1]  Sellers also moved for traditional summary judgment on the element of actual or constructive knowledge of the condition, relying on Garcia=s own testimony that she did not know how the liquid got on the floor, who placed it on the floor, or how long it had been on the floor before she stepped in it. 

In response, Garcia claimed that her testimony and that of Sellers= employees raised a fact issue on the first and second elements, because the amount of liquid on the floor and the half-empty, damaged container of liquid provided temporal evidence to show that Sellers should have discovered the puddle and failed to exercise reasonable care to get rid of the spill.  Garcia pointed to her deposition testimony concerning her injury to raise a fact issue on the third element.  Finally, Garcia sought to avoid summary judgment by claiming that Sellers spoliated evidence by (1) failing to preserve the container even though it anticipated litigation the same day Garcia fell, and (2) knowingly or negligently removing a surveillance videotape of the area where she fell shortly after the incident.

On appeal, Garcia raises two issues:  (1) the trial court erred in granting summary judgment because she presented competent summary judgment evidence that created genuine issues of material fact on the elements of her premises liability claim; and (2) the trial court erred by disregarding her spoliation claim, which would have precluded summary judgment.  We will address these issue in reverse order, beginning with Garcia=s spoliation issue.  See Aguirre v. S. Tex. Blood and Tissue Ctr.

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