Morris Davis v. Alice Oliver

CourtCourt of Appeals of Kentucky
DecidedMarch 28, 2025
Docket2024-CA-0027
StatusUnpublished

This text of Morris Davis v. Alice Oliver (Morris Davis v. Alice Oliver) 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
Morris Davis v. Alice Oliver, (Ky. Ct. App. 2025).

Opinion

RENDERED: MARCH 28, 2025; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2024-CA-0027-MR

MORRIS DAVIS APPELLANT

APPEAL FROM HOPKINS CIRCUIT COURT v. HONORABLE CHRISTOPHER BRYAN OGLESBY, JUDGE ACTION NO. 21-CI-00537

ALICE OLIVER APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: CALDWELL, COMBS, AND KAREM, JUDGES.

CALDWELL, JUDGE: Morris Davis (“Davis”) appeals from the Hopkins Circuit

Court’s denial of his motion for a missing-evidence instruction and granting of

summary judgment in favor of Alice Oliver (“Oliver). This is a negligence case

where Davis alleged Oliver supplied him with a dangerous and defective ladder.

We affirm the circuit court. FACTUAL AND PROCEDURAL BACKGROUND

Davis, a retired carpenter, met Oliver, a long-haul truck driver in

August of 2020, at her home in Dawson Springs, Kentucky to discuss the repair of

her roof. Davis went to Oliver’s home with a mutual acquaintance whose roof he

had repaired and through whom Oliver had contacted him. On that day, Oliver let

Davis use a ladder from her storage shed to climb onto the roof for inspection. In

later statements, Davis and Oliver would both recall the ladder was one made by

Little Giant Ladder Systems (“Little Giant”). After inspection of the roof, Davis

returned the ladder to Oliver’s storage shed. The price of $15 per hour was agreed

upon for the necessary work and Davis advised he would return.

Later, on August 31, 2020, Davis returned for the repair. Oliver was

home inside but Davis did not see or speak with her before retrieving the Little

Giant ladder from the storage shed to begin work. When placing the ladder for

access to the roof, Davis chose the same location he had for the inspection. As he

was climbing the ladder, after taking about four steps up, Davis felt the ladder

collapse and he fell. Hearing Davis’s fall, Oliver came from inside her house. She

observed the top half and bottom half of the ladder were in separate pieces on the

ground. Davis was taken to a medical provider and treated for injuries to his arm.

A letter of representation dated April 30, 2021, from Davis’s attorney

was sent to Oliver by certified mail. The letter requested she preserve the ladder.

-2- The letter additionally requested an opportunity to inspect the ladder. A response

to Davis’s attorney from a claims adjuster, dated May 5, 2021, stated:

In regards to your spoliation issue, the involved Little Giant Ladder is still in the possession of Ms. Oliver. Please contact our office to schedule a date and time for an inspection. We would appreciate the inspection being completed within the next 30 days, if possible.

For reasons not apparent from the record before us, no inspection occurred.

On August 7, 2021, Davis filed an action in Hopkins Circuit Court

against Oliver for negligence and Little Giant for a number of product liability

claims. Little Giant first moved to dismiss Davis’s claims against it on April 12,

2022, alleging Davis had failed to maintain and produce the ladder for inspection.

Davis cited to outstanding discovery in response and requests to Oliver for

information about the ladder. The trial court denied the motion, granting time for

discovery on the matter.

Interrogatory responses subsequently served by Oliver indicated she

was no longer in possession of the ladder. One response indicated that after

Davis’s accident it had been “put back in the building and we didn’t use it again. It

was taken from the building sometime after and not returned.” In another response

to an interrogatory inquiring whether Oliver had disposed of the ladder, she

responded: “I did not dispose of the ladder. It was ‘borrowed’ and not returned. I

don’t know who took the ladder.”

-3- Little Giant filed a renewed Motion to Dismiss on July 29, 2022.

Oliver filed her own Motion to Dismiss on August 4, 2022. Davis filed a Motion

in Limine for an Adverse Inference Jury Instruction on August 23, 2022. Davis

argued that, despite receiving a preservation letter from counsel, Oliver had failed

to preserve the ladder. Davis also cited to this issue in responses to both

defendants’ motions. The trial court denied both Davis’s and Oliver’s motions but

expressed willingness to revisit either following discovery, should the evidence

render them appropriate. However, all claims against Little Giant were dismissed

by an order of the trial court on August 30, 2022. That order is not subject to the

current appeal.

A deposition of Davis occurred on March 2, 2023. Counsel for Davis

deposed Oliver on May 1, 2023. Oliver filed a motion for summary judgment with

the trial court on August 22, 2023. On October 6, 2023, Davis filed a Renewed

Motion in Limine for an Adverse Inference Jury Instruction. After hearing oral

arguments, the trial court denied Davis’s motion and granted summary judgment to

Oliver on December 5, 2023. This appeal follows. Additional facts will be

developed as necessary.

ANALYSIS

Davis argues the trial court erroneously determined the evidence did

not support a missing-evidence instruction. Furthermore, Davis alleges the trial

-4- court erred in granting summary judgment to Oliver as there were genuine issues

of material fact appropriate for jury determination. We find no error in either

decision.

Standard of Review

For a trial court’s determination of whether to grant a missing

evidence instruction, we review pursuant to the abuse of discretion standard.

University Medical Center, Inc. v. Beglin, 375 S.W.3d 783, 790-91 (Ky. 2011).

In reviewing the trial court’s grant of summary judgment, we must

determine “whether the record, when examined in its entirety, shows there is no

genuine issue as to any material fact and the moving party is entitled to a judgment

as a matter of law.” Powers v. Kentucky Farm Bureau Mutual Insurance

Company, 694 S.W.3d 361, 374 (Ky. 2024). In so doing, we keep in mind that the

trial court “must view the evidence in a light most favorable to the nonmoving

party, resolving all doubts in its favor.” Id. Since summary judgment does not

entail the trial court’s making findings of facts but simply determining whether

genuine issues of material fact exist based on the record, appellate courts do not

defer to “the trial court's assessment of the record or its legal conclusions.” Id. In

other words, we review a trial court’s grant of summary judgment de novo –

meaning without any deference. Ashland Hospital Corporation v. Darwin Select

Insurance Co., 664 S.W.3d 509, 516 (Ky. 2022).

-5- I. Missing Evidence Instruction.

We will first address Davis’s argument that the trial court erred in

denying his motion(s) in Limine for an Adverse Inference Jury Instruction. Davis

cites to Ordway v. Commonwealth that “[t]he missing evidence instruction should

be given when material evidence within the exclusive possession and control of a

party, or its agents or employees, was lost without explanation or is otherwise

unaccountably missing[.]” 391 S.W.3d 762, 793 (Ky. 2013). Oliver’s sole

possession of the ladder was established by her own admission, Davis argues, and

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