Marshall, H. v. Brown's IA, LLC

CourtSuperior Court of Pennsylvania
DecidedMarch 27, 2019
Docket2588 EDA 2017
StatusPublished

This text of Marshall, H. v. Brown's IA, LLC (Marshall, H. v. Brown's IA, LLC) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Marshall, H. v. Brown's IA, LLC, (Pa. Ct. App. 2019).

Opinion

J-A27001-18

2019 PA Super 94

HARRIET MARSHALL : IN THE SUPERIOR COURT OF : PENNSYLVANIA Appellant : : : v. : : : BROWN’S IA, LLC : No. 2588 EDA 2017

Appeal from the Judgment Entered July 10, 2017 In the Court of Common Pleas of Philadelphia County Civil Division at No(s): September Term, 2015 No. 03279

BEFORE: BOWES, J., STABILE, J., and McLAUGHLIN, J.

OPINION BY BOWES, J.: FILED MARCH 27, 2019

Harriet Marshall appeals from the July 10, 2017 judgment in favor of

Appellee Brown’s IA, LLC, and alleges that she is entitled to a new trial because

the trial court erred in refusing to give an adverse inference instruction based

on Appellee’s spoliation of videotape evidence. We vacate the judgment and

remand for a new trial.

Brown’s IA, LLC (“ShopRite”) owns thirteen grocery stores, one being

the Island Avenue ShopRite in Philadelphia. On August 6, 2014, Ms. Marshall

slipped on water, fell in the produce aisle of the store, and aggravated a pre-

existing injury to her hip and back. ShopRite employees came to her aid and J-A27001-18

summoned medical assistance, and the manager completed an incident report

immediately thereafter.1

Approximately two weeks later, ShopRite received a letter of

representation from Ms. Marshall’s counsel requesting that ShopRite retain,

inter alia, surveillance video of the accident and area in question for six hours

prior to the accident and three hours after the accident. Additionally, the

letter cautioned:

If any of the above evidence exists, and you fail to maintain same until the disposition of this claim, it will be assumed that you have intentionally destroyed and/or disposed of evidence. Please be advised that you are not permitted, and are in no position, to decide what evidence plaintiff would like to review for this case. Accordingly, discarding any of the above evidence will lead to an Adverse Inference against you in this matter.

Plaintiff’s Exhibit 3 (letter from counsel, 8/18/14, at 1).

Ms. Marshall’s slip and fall was captured on the store’s video surveillance

system. However, ShopRite decided to preserve only thirty-seven minutes of

video prior to Ms. Marshall’s fall and approximately twenty minutes after, and

permitted the remainder to be automatically overwritten after thirty days.

Subsequently, counsel for ShopRite told the jury in his opening statement

____________________________________________

1 The incident report was prepared by Ashley Jones, the Human Resources Manager. She noted therein that Ms. Marshall stated that she was getting a pepper in the produce department when she slipped and fell on water. Ms. Jones testified at trial that although she could not remember seeing water on the floor, “[i]f I didn’t see it then I would put that on the report.” N.T. Jury Trial, 1/12/17, at 76, 78. The report contained no such notation.

-2- J-A27001-18

that, “it isn’t possible to tell from the video if there was water on the floor,

how it got there or when it got there.” N.T. Jury Trial, 8/6/14, at 42.2

ShopRite’s Risk Manager, Matthew McCaffrey, testified that it was

ShopRite’s “rule of thumb” to preserve video surveillance from twenty minutes

before and twenty minutes after a fall. He opined that the video produced

was sufficient to see the defective condition if it could be seen at all. Since

the substance on the floor could not be seen on the retained portion of the

video, he maintained it “would be a fool’s errand” to go back several hours as

requested. N.T. Jury Trial, 1/13/17, at 35. He added that it was impractical

and costly to retain the requested six hours of pre-incident videotape.

At trial, ShopRite offered evidence of its reasonable care in keeping the

store premises safe for customers. Managers testified that employees were

trained in the importance of preventing slip and falls, and described financial

incentives for employees who located and cleaned up spills. The store also

uses the Gleason system, an electronic monitoring system whereby, once per

hour, an employee walks around the store on a designated route that passes

thirty-five buttons. As the employee inspects the floor in each area near the

button, he or she uses an electronic wand to press the button indicating

whether there was a wet spill, dry spill, or the area was clear. The system

2 At the close of Plaintiff’s case, ShopRite moved for a non-suit, alleging that there was no evidence as to how the liquid got on the floor or how long it was there. The trial court denied the nonsuit.

-3- J-A27001-18

creates a log for each of the walk-throughs. The Gleason logs for the day of

Ms. Marshall’s fall indicated that the produce area where she fell was inspected

from 7:07:52 a.m. to 7:09:59 a.m., and again at 8:01:42 a.m. through

8:05:34 a.m. Trial Exhibit P-2. Ms. Marshall fell at approximately 8:54 a.m.,

almost fifty minutes after the last Gleason inspection.

Ms. Marshall contended below that ShopRite’s conscious decision not to

retain the video evidence constituted spoliation, and she asked the trial court

to give an adverse inference charge to the jury.3 N.T. Jury Trial, 1/14/17, at

14. ShopRite argued there was no relevant evidence as the video did not

show drops of water on the floor, and furthermore, it did not act in bad faith

in deleting the additional video requested. The trial court observed first that

the fact that the video was requested did not make it relevant. It concluded

further that there was no bad faith on the part of ShopRite, and refused to

give the requested adverse inference charge. The court did agree, however,

that Ms. Marshall’s counsel could argue to the jury that it should infer from

ShopRite’s decision not to retain more of the video prior to Ms. Marshall’s fall

that the video was damaging to ShopRite.

3 Pa.S.S.J.I. 5.60, relating to spoliation of evidence, provides:

If a party disposes of a piece of evidence before the other party had an opportunity to inspect it, and the party who disposed of the evidence should have recognized the evidence was relevant to an issue in this lawsuit, then you may find that this evidence would have been unfavorable to them, unless they satisfactorily explain why they disposed of this evidence.

-4- J-A27001-18

Counsel for Ms. Marshall told the jury in closing argument that ShopRite

made the conscious decision not to keep the video because it was harmful to

them, and that the water was on the floor long enough that, with reasonable

care, they should have seen and remedied it. Defense counsel countered,

But you have seen the video, you have seen the quality of the video. Is there really any expectation that if more video had been saved that we would have seen something, we would have seen when this obviously small spot of water that you can’t even see on the floor could have gotten on the floor?

N.T. Jury Trial, 1/17/17, at 71.

The jury returned a verdict in favor of ShopRite, finding no negligence.

Ms. Marshall filed timely post-trial motions alleging that she was entitled to a

new trial because the trial court erred in refusing to give the requested

spoliation instruction to the jury. The motion was deemed denied pursuant to

Pa.R.C.P. 227.4(1)(b), when more than one hundred and twenty days elapsed

and the trial court did not rule on the motion. Judgment was entered on July

10, 2017, and Ms. Marshall timely appealed. She raises one question for our

review:

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