Salazar v. Target Corporation

CourtDistrict Court, D. Nevada
DecidedNovember 13, 2019
Docket2:18-cv-01039
StatusUnknown

This text of Salazar v. Target Corporation (Salazar v. Target Corporation) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Salazar v. Target Corporation, (D. Nev. 2019).

Opinion

2 3 UNITED STATES DISTRICT COURT 4 DISTRICT OF NEVADA 5 * * * 6 MARIA SALAZAR, an individual, Case No. 2:18-cv-01039-MMD-EJY 7 Plaintiff, ORDER v. 8 TARGET CORPORATION, a foreign 9 corporation; DOE Individuals 1-10; DOE Employees 11–20, and ROE 10 CORPORATIONS 21–30., 11 Defendants. 12 13 I. SUMMARY 14 This is a slip-and-fall case. Defendant Target Corporation moves for summary 15 judgment on Plaintiff Maria Salazar’s claims for negligence and negligent hiring, training 16 and supervision (ECF No. 1-1) (“Motion”). (ECF No. 33.)1 The material issue before the 17 Court is whether Defendant had constructive notice of the spill on its floor. The Court 18 concludes that this issue must be decided by a jury. Therefore, the Court will deny 19 Defendant’s Motion. 20 II. BACKGROUND 21 The following facts are undisputed. 22 The incident arose in September 2016, while Plaintiff was shopping at the Target 23 store located at 3550 S. Rainbow Blvd., Las Vegas, NV (“Store”). (ECF No. 1-1 at 2.) While 24 walking in the frozen foods area of the Store, Plaintiff slipped on water and fell. (ECF No. 25 34-1 at 2, 12, 38.) Plaintiff testified during her deposition that she did not know where the 26 water came from or how long it had been on the floor. (ECF No. 33-1 at 6.) The Store’s 27 /// 28 1The Court has considered the parties’ briefs (ECF Nos. 33, 34) and accompanying exhibits (ECF No. 33-1, 34-1, 34-2). Defendant did not file a reply. 2 inquire about the floor being inspected and did not know how long the spill had been on 3 the floor. (ECF No. 34-1 at 13–14.) Macke also stated that the spill was about the size of 4 a 10 by 10 (or 12 by 12) inch tile and marked the incident as occurring approximately in 5 the middle of the aisle. (Id. at 12–13, 71 (Salazar 000245).) 6 Although Macke was unclear as to whether she assumed that Plaintiff had spilled 7 the water on the floor, Macke did not investigate further to determine any other causes. 8 (Id. at 13–14.) Plaintiff disputes that she or those with her spilled the water. (Id. at 35–37.) 9 There are no available video surveillance or photos related to the incident. (See 10 ECF No. 34-1 at 11, 53 (not indicating the existence of any such evidence), 57.) 11 Additionally, Target’s Rule 30(b)(6) witness and the Store’s director, Joseph Rudulph, 12 testified that he had no information regarding how the floors are inspected by employees. 13 (ECF No. 34-2 at 3, 14, 19.) Nor was he aware of any standards—aside from monthly 14 maintenance—in place regarding how often employees are supposed to inspect the floors 15 to prevent slip-and-fall incidents. (Id. at 18–19.) Rudulph testified that as a matter of 16 “general service” if employees see an issue they should address it. (Id. at 19.) 17 III. LEGAL STANDARD 18 “The purpose of summary judgment is to avoid unnecessary trials when there is no 19 dispute as to the facts before the court.” Nw. Motorcycle Ass’n v. U.S. Dep’t of Agric., 18 20 F.3d 1468, 1471 (9th Cir. 1994). Summary judgment is appropriate when the pleadings, 21 the discovery and disclosure materials on file, and any affidavits “show that there is no 22 genuine issue as to any material fact and that the moving party is entitled to a judgment 23 as a matter of law.” Celotex Corp. v. Catrett, 477 U.S. 317, 322 (1986). An issue is 24 “genuine” if there is a sufficient evidentiary basis on which a reasonable fact-finder could 25 find for the nonmoving party and a dispute is “material” if it could affect the outcome of the 26 suit under the governing law. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). 27 The moving party bears the burden of showing that there are no genuine issues of 28 material fact. Zoslaw v. MCA Distrib. Corp., 693 F.2d 870, 883 (9th Cir. 1982). Once the 2 motion to “set forth specific facts showing that there is a genuine issue for trial.” Anderson, 3 477 U.S. at 256. The nonmoving party “may not rely on denials in the pleadings but must 4 produce specific evidence, through affidavits or admissible discovery material, to show 5 that the dispute exists,” Bhan v. NME Hosps., Inc., 929 F.2d 1404, 1409 (9th Cir. 1991), 6 and “must do more than simply show that there is some metaphysical doubt as to the 7 material facts.” Orr v. Bank of Am., NT & SA, 285 F.3d 764, 783 (9th Cir. 2002) (quoting 8 Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 586 (1986)). “The mere 9 existence of a scintilla of evidence in support of the plaintiff’s position will be insufficient.” 10 Anderson, 477 U.S. at 252. Moreover, a court views all facts and draws all inferences in 11 the light most favorable to the nonmoving party. Kaiser Cement Corp. v. Fischbach & 12 Moore, Inc., 793 F.2d 1100, 1103 (9th Cir. 1986). 13 IV. DISCUSSION 14 Under Nevada law, “a business owes its patrons a duty to keep the premises in a 15 reasonably safe condition for use.” Sprague v. Lucky Stores, Inc., 849 P.2d 320, 322 (Nev. 16 1993) (citing Asmussen v. New Golden Hotel Co., 392 P.2d 49, 49 (1964)). However, that 17 an incident occurred resulting in injury is not sufficient to establish liability. Gunlock v. New 18 Frontier Hotel, 370 P.2d 682, 684 (1962), abrogated on other grounds by Foster v. Costco 19 Wholesale Corp., 291 P.3d 150, 156 (Nev. 2012). The plaintiff must demonstrate 20 negligence. Id. “Where a foreign substance on the floor causes a patron to slip and fall, 21 and the business owner or one of its agents caused the substance to be on the floor, 22 liability will lie, as a foreign substance on the floor is usually not consistent with the 23 standard of ordinary care.” Sprague, 849 P.2d at 322 (citations omitted). In cases where 24 the foreign substance results from the actions of “persons other than the business or its 25 employees, liability will lie only if the business had actual or constructive notice of the 26 condition and failed to remedy it.” Id. at 322–23. (citations omitted). Here, Defendant 27 challenges only the existence of notice and Plaintiff specifically contends only that 28 /// 2 Accordingly, the Court addresses solely the issue of constructive notice. 3 Whether constructive notice exists is generally a question of fact for a jury to decide. 4 Id. at 323. Defendant argues that the Court should grant summary judgment in its favor 5 because Plaintiff lacks sufficient evidence that Defendant (or its employees) had 6 constructive notice of the spill. (ECF No. 33 at 6–7.) Defendant’s position is chiefly that 7 Plaintiff needs to show that the water had been on the floor long enough to be a continuous 8 condition to establish constructive notice and that Plaintiff’s deposition testimony is 9 insufficient to do so. (Id. (pointing to Spraque as a case where constructive notice was 10 found based on the existence of continual debris on the floor).) Plaintiff argues that 11 constructive notice may be based on whether the business exercised its duty of 12 reasonable care to its patrons by taking appropriate steps under the circumstances. (ECF 13 No.

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Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
United States v. Michael Leslie Blaylock
20 F.3d 1458 (Ninth Circuit, 1994)
Robin Orr v. Bank of America, Nt & Sa
285 F.3d 764 (Ninth Circuit, 2002)
Sprague v. Lucky Stores, Inc.
849 P.2d 320 (Nevada Supreme Court, 1993)
Asmussen v. New Golden Hotel Company
392 P.2d 49 (Nevada Supreme Court, 1964)
Gunlock v. New Frontier Hotel Corp.
370 P.2d 682 (Nevada Supreme Court, 1962)
Foster v. Costco Wholesale Corp.
291 P.3d 150 (Nevada Supreme Court, 2012)

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Salazar v. Target Corporation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/salazar-v-target-corporation-nvd-2019.