PATTI PENNINGTON v. BRIDGE SENIOR LIVING, LLC

CourtCourt of Appeals of Georgia
DecidedNovember 3, 2023
DocketA23A0883
StatusPublished

This text of PATTI PENNINGTON v. BRIDGE SENIOR LIVING, LLC (PATTI PENNINGTON v. BRIDGE SENIOR LIVING, LLC) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
PATTI PENNINGTON v. BRIDGE SENIOR LIVING, LLC, (Ga. Ct. App. 2023).

Opinion

THIRD DIVISION DOYLE, P. J., GOBEIL, J., and SENIOR JUDGE FULLER

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules

November 3, 2023

In the Court of Appeals of Georgia A23A0883. PENNINGTON et al. v. BRIDGE SENIOR LIVING, LLC et al.

DOYLE, Presiding Judge.

Patti Pennington, individually and as administrator of the estate of her deceased

husband, brought this premises liability action to recover damages after her husband

tripped and fell on an uneven pavement seam near the entrance to their assisted living

facility. The trial court granted summary judgment to the defendants on the ground

that they lacked superior knowledge of the hazard, and Pennington appeals. Because

the undisputed evidence shows that the hazard was a commonly occurring open and

obvious static condition, we affirm. Viewed in the light most favorable to Pennington as the non-movant,1 the

record shows that she and her husband moved into Somerby Sandy Springs, an

assisted living facility, in January 2018. The facility had been built about a year

earlier, and its main entrance had a hotel-style passenger loading area beneath a

covered portico. When the couple moved in, Pennington’s husband, Dr. Edward Earl

Pennington, was 79 years old and had various health problems, though he was

independently ambulatory. One evening in April 2020, Pennington and her husband

drove to a local restaurant, then returned to Somerby. They exited their car and

walked across the parking lot toward the facility’s main entrance. As Pennington’s

husband crossed the seam between the asphalt driveway and the concrete pavement

at the portico entrance, he tripped and fell, incurring serious injuries that led to his

death several days later. According to Pennington, despite living there for more than

two years, she only used the area for loading and unloading when she was by herself,

1 See D’Elia v. Phillips Edison & Co., 354 Ga. App. 696, 697 (839 SE2d 721) (2020) (in reviewing a trial court’s grant of summary judgment, “we apply a de novo standard of review, and we view the evidence, and all reasonable conclusions and inferences drawn from it, in the light most favorable to the nonmovant”) (citation and punctuation omitted).

2 and she had never traversed that pavement seam on foot because, “There is no reason

to. There is a sidewalk which is covered.”2

Pennington filed a premises liability action against Somerby’s owner, manager,

and director (collectively, “Somerby”), alleging that her husband’s injuries had been

caused by “an unmarked, uneven, raised change in the pavement.” Asserting claims

for negligence and negligence per se, the complaint alleged that Somerby knew or

should have known about this height differential, which violated multiple applicable

codes and standards, but neither repaired it nor warned residents of it.

Pennington engaged Richard Rice, a licensed professional and structural

engineer, to “review the evidence” and “determine whether or not any codes or

standards were violated that would have caused [the decedent] to trip and fall.” Rice

measured a maximum height discrepancy of seven-sixteenths of an inch between the

asphalt pavement and concrete slab at the seam. According to Rice, codes and

standards applicable under Georgia law to assisted living facilities are meant to

protect “those who have ambulatory problems” and prohibit changes in level that are

2 There is no evidence in the record as to whether Dr. Pennington had ever traversed that area of the driveway before he fell.

3 greater than one-fourth of an inch at accessible routes and means of egress.3 Rice

testified that the seam between the two surfaces was clearly visible, but the height

differential was not discernible to the average person crossing the seam because

“[t]hey’re not looking for it.” Rice concluded that the two surfaces were level and

code-compliant when constructed, but the asphalt later settled at a lower level than

the concrete as the pavement subgrade consolidated. Rice further opined that the

height discrepancy had existed “for quite an amount of time.”

Pennington also obtained the affidavit of a former Somerby employee who

stated that in 2019, she “tripped on an unlevel part of the concrete near the entrance

to” the facility. The former employee averred that she had told some co-workers what

happened “because [she] was concerned that elderly people who live at Somerby

might trip on the same place where [she] had tripped, and get injured.” According to

3 Specifically, Rice cited the Georgia State Minimum Fire Safety Standards, which in turn adopt the National Fire Protection Association’s Life Safety Code. See Ga. Comp. R. & Regs., r. 120-3-3-.02 (73). That code provides that “[w]alking surfaces in the means of egress” at residential boarding facilities may not include “[a]brupt changes in elevation . . . . exceed[ing] 1/4 in.” Rice also cited the State Minimum Accessibility Standards, which provide that “[c]overed multifamily dwellings” must meet the “2003 edition of the ANSI A117.1 standard entitled ‘Accessible and Usable Buildings and Facilities[.]’” Ga. Comp. R. & Regs., r. 120-3- 20.04 (1). Under that standard, vertical changes in the level of a floor surface cannot exceed one-fourth of an inch. For the purposes of summary judgment, Somerby does not challenge the applicability of these standards.

4 the former employee, she later learned that she had tripped in “the same spot” where

the decedent had fallen. The former employee declined to identify which co-workers

she told about her fall,4 and Somerby’s corporate representative testified that the

former employee “never reported this incident” and that Somerby has no

documentation of it.

Somerby moved for summary judgment, arguing among other things that it

lacked superior knowledge of the pavement defect over which the decedent tripped.

The trial court granted Somerby’s motion, ruling that the defect was a static condition

of which Dr. Pennington had equal knowledge, and this knowledge prohibited

recovery even assuming that the seam was a building code violation. Pennington

appeals.

Pennington argues that the trial court erred by granting Somerby’s motion

because routine issues of premises liability should not be adjudicated summarily and

4 On motion by Somerby, the trial court struck as inadmissible hearsay a paragraph from the former employee’s affidavit recounting what her co-workers had told Pennington, and Pennington does not challenge that ruling here.

5 there was evidence that Somerby had superior knowledge of the defect.5 Based on the

record in this case, we disagree.

Under OCGA § 51-3-1,

[w]here an owner or occupier of land, by express or implied invitation, induces or leads others to come upon his premises for any lawful purpose, he is liable in damages to such persons for injuries caused by his failure to exercise ordinary care in keeping the premises and approaches safe.

To prevail on a premises liability claim, the plaintiff must show “(1) that the

defendant had actual or constructive knowledge of the hazard; and (2) that the

[injured party] lacked knowledge of the hazard despite the exercise of ordinary care

due to actions or conditions within the control of the owner/occupier.”6 Therefore,

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