PHILLIP S. HOWARD v. CTW ENTERPRISES, INC.

CourtCourt of Appeals of Georgia
DecidedMarch 21, 2023
DocketA23A0038
StatusPublished

This text of PHILLIP S. HOWARD v. CTW ENTERPRISES, INC. (PHILLIP S. HOWARD v. CTW ENTERPRISES, INC.) 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
PHILLIP S. HOWARD v. CTW ENTERPRISES, INC., (Ga. Ct. App. 2023).

Opinion

THIRD DIVISION DOYLE, P. J., GOBEIL, J., and SENIOR APPELLATE JUDGE PHIPPS

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

March 21, 2023

In the Court of Appeals of Georgia A23A0038. HOWARD v. CTW ENTERPRISES, INC. et al.

PHIPPS, Senior Appellate Judge.

Phillip S. Howard, a customer at CTW Enterprises, Inc., d/b/a Mill Creek Car

Wash & Lube (“CTW”), brought this premises liability action against CTW and its

manager, alleging that he suffered injuries after falling into a work pit. The trial court

granted summary judgment to the defendants, ruling that the pit was a static condition

of which Howard had equal knowledge and that he failed to exercise ordinary care

for his own safety. Howard appeals, but we find no error and affirm.

Summary judgment is appropriate when there is no genuine issue of material fact and the movant is entitled to judgment as a matter of law. In reviewing the grant or denial of a motion for 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. D’Elia v. Phillips Edison & Co., 354 Ga. App. 696, 697 (839 SE2d 721) (2020)

(citation and punctuation omitted).

So viewed, the record shows that on the day he fell, Howard was 81 years old

and had retired after working for many years in the used car industry. Howard had

been visiting CTW “once every two weeks” for the previous 15 years, had brought

“a number of cars” there to be serviced, and was “literally a friend with everybody

that worked there.” According to Howard, the facility had three service bays, each

containing a “zip pit” to allow employees to work underneath customers’ vehicles.

The pits were four to five feet deep and were located roughly ten to twelve feet inside

the front garage door of each bay. Although Howard usually sat in a chair outside the

pit area while employees worked on his car, he had “walked in the bay” at least once

before while having his car emissions checked. Howard testified that CTW’s layout

had remained “about the same” over the past 15 years and the pits had been there the

entire time.

On the day of the incident, Howard brought his car to CTW to have the

headlights balanced and fluids checked. He sat in his customary chair while an

employee brought his car up to the bay. Howard described what happened next:

2 And then when [the employee] brought the car in, he said Phil, come up here by the front of the car, if you will, and get down low so you can see if these lights are lined up. I’m trying to adjust them, I can’t tell. Well, at this time, I’m in front of the pit facing the front door, and the pit is behind me, so I can’t see the pit. I’m relying on him, who was up front in the car looking at me down on my knees. I said, well, I can’t really tell if they’re lined up properly or not. He says you need to back up about two more feet. So I was following his instructions, assuming he could see the pit because I couldn’t, [and] when I backed up under his instructions, I fell into the pit.

Describing his positioning, Howard testified that he “got down [i]n a crouch” in front

of the headlights and moved “straight back” at the employee’s request. He knew the

pit was behind him, but did not realize how close it was and did not look before

backing up.

After Howard landed in the pit, the employee expressed concern and told him

not to move, but CTW’s general manager Young Lee berated Howard for being in the

pit, then “got in his car and left” without offering assistance. Other CTW employees

helped Howard out of the pit and offered to call an ambulance, but Howard declined

and drove himself to his doctor’s office. He suffered multiple injuries as a result of

the fall.

3 Howard sued CTW and Lee, alleging that his injuries resulted from their

negligent failure to keep the premises safe. Howard filed a motion for partial

summary judgment on the issue of liability,1 and the defendants filed a cross-motion

for summary judgment on all claims. Following a hearing, the trial court granted the

defendants’ motion, ruling that Howard had equal knowledge of the pit, which was

an open and obvious static condition, and that he failed to exercise ordinary care for

his own safety.2 Howard appeals, challenging both rulings.

The basic law of premises liability is well established:

[A] plaintiff must show (1) that the defendant had actual or constructive knowledge of the hazard; and (2) that the plaintiff lacked knowledge of the hazard despite the exercise of ordinary care due to actions or conditions within the control of the owner/occupier. Accordingly, the fundamental basis for an owner or occupier’s liability is that party’s superior knowledge of the hazard encountered by the plaintiff. In other

1 Howard also filed a “Motion for Spoliation and Punitive Damages Jury Instruction,” alleging that the defendants had knowingly deleted a video recording of the incident. The defendants responded that CTW’s video camera system automatically overwrites itself every 27.5 days, so “any video footage of the incident would have been automatically overwritten before any duty to preserve could have attached.” The record contains no ruling on this motion. 2 Although the trial court did not specifically address Howard’s motion for partial summary judgment, it characterized its order as a “final judgment on the merits resolving all claims against the Defendants.”

4 words, a plaintiff is not entitled to recovery if the undisputed evidence demonstrates that the plaintiff’s knowledge of the hazard was equal to or greater than that of the defendant.

Crebs v. Bass Pro Outdoor World, 360 Ga. App. 121, 122-123 (860 SE2d 802)

(2021) (citation and punctuation omitted). As the trial court observed, this case

involves a static condition, which is “one that does not change and is dangerous only

if someone fails to see it and walks into it.” D’Elia, 354 Ga. App. at 698 (citation and

punctuation omitted). “[I]f nothing obstructs the [plaintiff’s] ability to see the static

condition, the proprietor may safely assume that the [plaintiff] will see it and will

realize any associated risks.” Id. at 699 (citation and punctuation omitted).

Here, Howard had visited CTW every other week for 15 years, or about 390

times. He was familiar with the layout of the premises, which had not fundamentally

changed during those 15 years. He was aware of the pits and could describe them in

detail from memory. On the day of the incident, when Howard crouched down to look

at his car’s headlights, he knew the pit was behind him; and when he backed up, he

knew he was moving toward the pit. There is no evidence that anything blocked or

5 obstructed his view of the pit.3 Thus, the undisputed evidence shows that Howard’s

knowledge of the pit was equal to that of the defendants. See Crebs, 360 Ga. App. at

123. See also Morrison v. Anderson, 221 Ga. App. 396, 397 (1) (471 SE2d 329)

(1996) (affirming grant of summary judgment to proprietor where invitee fell off a

loading dock at a restaurant he had visited “three or four times a week for ten years,”

the edge of the loading dock “was in plain view,” and the invitee had equal

knowledge of any hazard).

Howard argues that his awareness of the pit does not insulate the defendants

from liability. He cites Brown-Legette v. QuikTrip, No.

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Related

Nosiri v. Helm
687 S.E.2d 635 (Court of Appeals of Georgia, 2009)
Morrison v. Anderson
471 S.E.2d 329 (Court of Appeals of Georgia, 1996)
Roberts v. Carter
448 S.E.2d 239 (Court of Appeals of Georgia, 1994)
Bartlett v. McDonough Bedding Co.
722 S.E.2d 380 (Court of Appeals of Georgia, 2012)
Pirkle v. Quiktrip Corp.
754 S.E.2d 387 (Court of Appeals of Georgia, 2014)

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