Pettyjohn, E. v. Chester Downs, Etc.

CourtSuperior Court of Pennsylvania
DecidedApril 19, 2022
Docket1271 EDA 2021
StatusUnpublished

This text of Pettyjohn, E. v. Chester Downs, Etc. (Pettyjohn, E. v. Chester Downs, Etc.) 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
Pettyjohn, E. v. Chester Downs, Etc., (Pa. Ct. App. 2022).

Opinion

J-A26043-21

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT I.O.P. 65.37

ELEANORA PETTYJOHN : IN THE SUPERIOR COURT OF : PENNSYLVANIA Appellant : : : v. : : : CHESTER DOWNS AND MARINA, LLC, : No. 1271 EDA 2021 D/B/A HARRAH’S PHILADELPHIA : CASINO AND RACETRACK :

Appeal from the Judgment Entered May 25, 2021 In the Court of Common Pleas of Delaware County Civil Division at No(s): 2019-002508

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

MEMORANDUM BY McCAFFERY, J.: FILED APRIL 19, 2022

Eleanora Pettyjohn (Pettyjohn) appeals from the judgment entered in

the Delaware County Court of Common Pleas after the trial court granted

summary judgment in favor of Chester Downs and Marina, LLC, d/b/a Harrah’s

Philadelphia Casino and Racetrack (Casino), in this personal injury action. On

appeal, Pettyjohn contends the trial court abused its discretion or committed

an error of law by: (1) determining Pettyjohn failed to prove she had a right

to relief under Section 343 of the Restatement (Second) of Torts; (2) failing

to consider Pettyjohn’s right to relief under Section 344 of the Restatement;

(3) failing to consider the fact that Casino participated in the spoliation of

evidence; (4) failing to state the reasons for its decision on the record or in a

written opinion; (5) failing to examine the entire record before granting

summary judgment; and (6) denying Pettyjohn due process of law when it J-A26043-21

neglected to rule upon her petition for reconsideration in a timely manner.

Because we conclude Pettyjohn proffered sufficient evidence to create a

genuine issue of material fact concerning her right to relief under Section 343

of the Restatement, we reverse the order granting summary judgment in favor

of Casino, and remand for further proceedings.

The relevant facts and procedural history are as follows. On September

5, 2017, Pettyjohn was a customer at Casino “when she was caused to lose

her footing and fall[.]” Pettyjohn’s Complaint 3/21/19, at ¶ 5. She avers that

the area of carpet where she fell “contained a defective condition.” Id. In

her answers to Casino interrogatories, Pettyjohn explained: “My foot felt like

it got caught up in a tear or rip in the carpet[.]” Casino Motion for Summary

Judgment, 2/2/21, Exhibit C, Pettyjohn’s Answers to Interrogatories, at 2

(unpaginated). See also id. at Exhibit D, Deposition of Pettyjohn, 12/19/19

(Pettyjohn Deposition), at 47 (stating she thought “it was a tear in the carpet”

that caused her to fall). As a result of the fall, Pettyjohn sustained significant

injuries, including a left hip fracture which required surgery. See Pettyjohn’s

Complaint at ¶ 9.

On March 21, 2019, Pettyjohn filed a civil complaint alleging Casino

failed to, inter alia, maintain the carpet or inspect it for defects, and that

Casino’s negligence was the cause of her injuries. See Pettyjohn’s Complaint

at ¶¶ 8-9. Casino filed an answer with new matter on April 24, 2019. On

December 11, 2020, the court entered an order, scheduling trial for the April

2021 term. See Order, 12/11/20, at 1. The order further directed that any

-2- J-A26043-21

motions for summary judgment be filed no later than 60 days before the trial

term. Id.

On January 26, 2021, Pettyjohn’s counsel, Robert G. Mangold, Esquire,

took the deposition of Casino’s Security and Risk Manager, Lawrence Moore.

Pettyjohn’s Petition for Reconsideration of this Court’s Order Granting Casino’s

Motion for Summary Judgment, 6/2/21, Exhibit C, Deposition of Lawrence

Moore, 1/26/21 (Moore Deposition), at 11.1 During the deposition, Attorney

Mangold requested additional discovery from Casino including, inter alia, “any

records involving the replacement of the carpet [i]n the area of the fall.”2 Id.

at 46.

Before providing any additional discovery, Casino filed a motion for

summary judgment on February 2, 2021.3 Casino argued that Pettyjohn

failed to produce sufficient evidence that it breached a duty owed to her. See

Casino’s Memorandum of Law in Support of its Motion for Summary Judgment,

2/2/21, at 8. Specifically, Casino asserted that Pettyjohn failed to prove the

____________________________________________

1 Although selected pages from Moore’s deposition were attached to Casino’s motion for summary judgment (Exhibit E) and Pettyjohn’s answer thereto (Exhibit B), the entire deposition is attached to Pettyjohn’s June 2, 2021, Petition for Reconsideration as Exhibit C.

2 In addition, a “Rider” was attached to the notice of Moore’s deposition which requested, among other things, the “[d]ate of carpet installation, repairs and nature of repairs to carpet[.]” Deposition of Moore, Exhibit 1, Rider to Notice of Deposition.

3 February 2nd was 58 days before the April 1st trial term.

-3- J-A26043-21

area of the carpet where she fell was in a dangerous condition, and even if so,

that Casino had actual or constructive notice of the danger. Id. at 9-11.

On February 16, 2021, Attorney Mangold sent a follow-up letter to

Casino’s attorney regarding the supplemental discovery requests he made

during Moore’s deposition. Pettyjohn’s Petition for Reconsideration, Exhibit D,

Letter from Mangold to Casino’s Attorney, 2/16/21. His request included

“[a]ny document that is related to the replacement of the casino carpets in

the area of [Pettyjohn’s] fall.” Id.

On March 5, 2021, Pettyjohn filed an answer to Casino’s motion for

summary judgment, asserting she produced sufficient evidence to submit her

case to a jury.4 In support of her claim, Pettyjohn attached an affidavit from

witness, Savette Taylor, who averred she was present at Casino at the time

of Pettyjohn’s fall, and accompanied Pettyjohn to the hospital. Pettyjohn’s

Answer to Casino’s Motion for Summary Judgment, 3/5/21, Exhibit A, Affidavit

of Savette Taylor, 3/2/21 (Taylor Affidavit) at 1 (unpaginated). Taylor further

attested that, while at the hospital, she

noticed something protruding out of [Pettyjohn’s] left sneaker which looked like a piece of carpet at the casino. When [she] ____________________________________________

4 Pursuant to Pennsylvania Rule of Civil Procedure 1035.3, an adverse party has 30 days to file a response to a motion for summary judgment, which, in this case, would have been March 4, 2021. See Pa.R.C.P. 1035.3(a). The trial court noted in its opinion that although Pettyjohn’s response was untimely (by one day), it was “not so much so that the [c]ourt [would] disregard it.” Order, 3/24/21, at 1 n.1. See Pa.R.C.P. 1035.3, Explanatory Cmt.-1996 (noting the “rule permits entry of judgment for failure to respond to the motion but does not require it”).

-4- J-A26043-21

looked closely, it was stuck between the sole and the main part of the shoe and it was protruding out. It was not on her shoe but locked in between the sole which was partly detached.

Id. Taylor stated she took a picture of the shoe. Id. She also claimed she

returned to the casino, and noticed that the carpet in the area Pettyjohn fell

“had pieces . . . that were sticking up” and “looked frayed and torn.” Id. It

merits mention that despite reference to the photograph of Pettyjohn’s shoe,

no photo was attached to Taylor’s affidavit or Pettyjohn’s answer.5

On May 25, 2021, the trial court entered an order granting Casino’s

motion for summary judgment and dismissing Pettyjohn’s claims with

prejudice.6 See Order, 5/25/21, at 9.

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