Pitts, K. v. Sonesta International Hotels Corp.

CourtSuperior Court of Pennsylvania
DecidedJune 23, 2026
Docket2834 EDA 2025
StatusUnpublished
AuthorMurray

This text of Pitts, K. v. Sonesta International Hotels Corp. (Pitts, K. v. Sonesta International Hotels Corp.) 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
Pitts, K. v. Sonesta International Hotels Corp., (Pa. Ct. App. 2026).

Opinion

J-S15025-26

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

KIMBERLY PITTS : IN THE SUPERIOR COURT OF : PENNSYLVANIA Appellant : : : v. : : : SONESTA INTERNATIONAL HOTELS : No. 2834 EDA 2025 CORPORATION A/K/A SONESTA : RITTENHOUSE A/K/A SONESTA : RITTENHOUSE SQUARE, AND ROYAL : SONESTA PHILADELPHIA, AND HPT : IHG-3 PROPERTY TRUST, AND CENTER : CITY HOTEL ASSOCIATES, AND JOHN : DOE (1-5) :

Appeal from the Judgment Entered August 19, 2025 In the Court of Common Pleas of Philadelphia County Civil Division at No(s): 231002600

BEFORE: OLSON, J., MURRAY, J., and STEVENS, P.J.E.*

MEMORANDUM BY MURRAY, J.: FILED JUNE 23, 2026

Kimberly Pitts (Appellant) appeals from the judgment entered against

her, and in favor of Sonesta International Hotels Corporation a/k/a Sonesta

Rittenhouse a/k/a Sonesta Rittenhouse Square, and Royal Sonesta

Philadelphia, and HPT IHG-3 Property Trust, and Center City Hotel Associates

(collectively, Sonesta), and John Doe (Doe) (all defendants referred to as the

Defendants). Appellant had filed the instant negligence action against

Defendants, seeking damages for injuries she sustained after falling on a wet

____________________________________________

* Former Justice specially assigned to the Superior Court. J-S15025-26

floor in the foyer/vestibule between Sonesta’s hotel’s lobby and an adjacent

parking garage not owned by Sonesta. The judgment resulted from the trial

court granting Defendants’ motion for compulsory nonsuit, following

Appellant’s case-in-chief, during the bench trial. After careful consideration,

we affirm.

The trial court summarized the facts underlying the instant appeal as

follows:

On or about November 7, 2021, [] Appellant was walking through the foyer [(foyer or vestibule)] of the Sonesta Hotel in Philadelphia, … when she allegedly slipped on the floor, causing injuries.

At the time of the accident, Appellant had just finished her shift as an employee of Ruth’s Chris Steakhouse. That business operated inside the Sonesta Hotel [(the hotel)]. Appellant walked from Ruth’s Chris through the common lobby and out [of] the door of the foyer leading to the hotel’s parking [garage]. Appellant claims she slipped and fell inside the hotel foyer because the foyer floor was wet.

Among the evidence presented at trial was the hotel lobby video showing Leonard Wilson [(Wilson)], [the hotel’s] maintenance technician, who is clearly seen inside the foyer mopping the floor prior to Appellant’s fall.

Per the video, the foyer at the time of the incident was well-lit[,] with large glass doors covering both the entrance from the hotel parking [garage] into the hotel foyer[,] and from the hotel lobby into the foyer on the other side.

Specifically, that video (shown numerous times throughout the trial) showed Wilson placing two (2) yellow warning signs inside the foyer with him as he is mopping; one sign appeared to be placed near the front doors’ entrance from the lobby into the foyer and one in front of the door leading from the foyer into the parking [garage,] respectively.

-2- J-S15025-26

Trial Court Opinion, 11/24/25, at 2-3 (unpaginated).

On October 25, 2022, Appellant filed the instant negligence action

against Defendants, to which Defendants filed an answer and new matter.

The matter proceeded through discovery. On March 3, 2025, Defendants filed

a motion for summary judgment, which the trial court denied on May 6, 2025.

A bench trial took place from July 14-17, 2025. At the close of

Appellant’s case-in-chief, Defendants moved for entry of a compulsory

nonsuit, which the trial court granted. Order, 7/29/25. Appellant filed a

motion to remove the nonsuit, which the trial court denied. On August 19,

2025, the trial court entered judgment in favor of Defendants, after which

Appellant timely filed the instant appeal. Appellant and the trial court have

complied with Pa.R.A.P. 1925.

Appellant presents the following issues for our review:

1. Whether the trial court, when considering []Appellant’s motion to remove entry of nonsuit, committed an error of law by usurping the function of the factfinder and resolving disputed issues of material fact?

2. Whether the trial court, when considering []Appellant’s motion to remove entry of nonsuit, committed an error of law by failing to resolve evidentiary conflicts or make inferences to the benefit of the non-moving party?

Appellant’s Brief at 5.

We address Appellant’s claims together, and review them under the

following standard:

A trial court may enter a compulsory nonsuit on any and all causes of action if, at the close of the plaintiff’s case against all

-3- J-S15025-26

defendants on liability, the court finds that the plaintiff has failed to establish a right to relief. Absent such finding, the trial court shall deny the application for a nonsuit. On appeal, entry of a compulsory nonsuit is affirmed only if no liability exists based on the relevant facts and circumstances, with appellant receiving the benefit of every reasonable inference and resolving all evidentiary conflicts in [the appellant’s] favor. The compulsory nonsuit is otherwise properly removed and the matter remanded for a new trial.

The appellate court must review the evidence to determine whether the trial court abused its discretion or made an error of law.

Baird v. Smiley, 169 A.3d 120, 124 (Pa. Super. 2017) (internal citations and

quotation marks omitted).

Appellant first argues that in entering the compulsory nonsuit, the trial

court improperly resolved factual issues against her, the non-moving party.

Appellant’s Brief at 33. Appellant claims she produced evidence establishing

that (1) her injury was caused by a dangerous condition, (2) the condition

was created by Defendants, who had notice of it, and (3) Defendants failed to

exercise reasonable care to protect her, as an invitee. Id. at 33-34. Appellant

states it is undisputed that “the vestibule floor was wet” before Appellant

entered. Id. at 34. Appellant claims that Defendants further admitted, in

their summary judgment motion and supporting bench memorandum, that

Defendants’ employee caused the floor to be wet, by mopping the floor “only

a minute or two before Appellant’s fall.” Id. Appellant argues that these facts

“evince [that Defendants] created a dangerous condition which [Appellant]

could not reasonably expect to discover and which [Defendants] had actual

-4- J-S15025-26

notice of.” Id. According to Appellant, this evidence established a prima facie

negligence cause of action against Defendants. Id. at 34-35.

Appellant acknowledges Defendants’ argument that the wet floor was

an open and obvious danger, and Defendants’ placement of “wet floor” signs

de facto satisfied any duty owed to Appellant. Id. at 35. Appellant claims

that these arguments are belied by the facts. Id. Appellant points out that

whether an “open and obvious danger” exists is a question of fact, which may

only serve as grounds for a nonsuit where “reasonable minds could not differ

as to the conclusion.” Id. at 36.

Appellant also argues that the wet-floor danger was not known and

obvious to her as a matter of law. Id. at 36-37. In support, Appellant relies

on her own testimony that she had no knowledge of the dangerous condition

before she fell. Id. at 37. According to Appellant, in the intervening period

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