Short v. CSS Audio, Inc.

2023 IL App (4th) 220479-U
CourtAppellate Court of Illinois
DecidedFebruary 7, 2023
Docket4-22-0479
StatusUnpublished

This text of 2023 IL App (4th) 220479-U (Short v. CSS Audio, Inc.) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Short v. CSS Audio, Inc., 2023 IL App (4th) 220479-U (Ill. Ct. App. 2023).

Opinion

NOTICE 2023 IL App (4th) 220479-U This Order was filed under FILED NO. 4-22-0479 February 7, 2023 Supreme Court Rule 23 and is Carla Bender not precedent except in the 4th District Appellate limited circumstances allowed IN THE APPELLATE COURT Court, IL under Rule 23(e)(1). OF ILLINOIS

FOURTH DISTRICT

SARAH SHORT, ) Appeal from the Plaintiff-Appellant, ) Circuit Court of v. ) Peoria County CSS AUDIO, INC. and PREMIERE AUDIO-VISUAL, ) No. 18L124 INC., ) Defendants-Appellees. ) Honorable ) Michael D. Risinger, ) Judge Presiding.

PRESIDING JUSTICE DeARMOND delivered the judgment of the court. Justices Cavanagh and Doherty concurred in the judgment.

ORDER ¶1 Held: The appellate court affirmed, finding defendants were entitled to judgment as a matter of law.

¶2 In November 2018, plaintiff, Sarah Short, filed a first-amended complaint against

defendants, CSS Audio, Inc. (CSS Audio) and Premiere Audio-Visual, Inc. (Premiere), seeking

damages for injuries she suffered when a Genie lift, owned by CSS Audio, fell on her as she

unloaded it from Premiere’s trailer. In March 2022, defendants filed separate motions for

summary judgment. Following a May 2022 hearing, the circuit court granted judgment in

defendants’ favor. Plaintiff appeals, arguing the court’s decision was in error. We affirm.

¶3 I. BACKGROUND ¶4 In November 2018, plaintiff filed a complaint alleging one count of negligence

against defendants. The complaint alleged that on February 1, 2018, plaintiff and another Peoria

Civic Center employee were unloading a Genie lift—a ground-supported device similar to a

forklift and operated by crank—owned by CSS Audio from Premiere’s trailer onto the civic

center’s loading dock. As plaintiff moved the lift down the trailer’s ramp, “the Genie lift got

stuck or the wheels were otherwise not rolling properly when [it] reached the loading dock,”

which caused the lift to fall on plaintiff. The complaint alleged defendants “had a duty to

exercise ordinary and reasonable care to see that the aforesaid trailer and ramp was reasonably

safe for the use of those lawfully upon and in the premises.” Plaintiff contended defendants

violated that duty by committing one or more of the following acts:

“a. Failed to take remedial measures to correct the dangerous condition of the

improperly placed and/or installed ramp at the aforesaid location;

b. Failed to warn employees of [the civic center], including the Plaintiff, of the

dangers that existed at the aforesaid location;

c. Permitted the Genie lift to be unloaded by an improperly placed and/or installed

ramp from the aforementioned trailer to the loading dock;

d. Failed to ensure that there were a sufficient number of people to unload the

Genie lift from the aforementioned trailer to the loading dock;

e. Negligently backed the aforementioned trailer into the loading dock of the

Peoria Civic Center so as to permit an unsafe condition to exist for unloading;

f. Negligently placed the unloading ramp from the aforementioned trailer to the

loading dock so as to permit a dangerous and unsafe condition to exist;

-2- g. Negligently supervised the unloading of the equipment from the

aforementioned trailer to the loading dock;

h. Negligently and inadequately supervised the unloading of the equipment;

i. Negligently provided dangerous and/or unsafe conditions to the employees of

[the civic center], including the Plaintiff, at or near the loading dock;

j. Negligently understaffed the unloading of equipment owned by CSS [Audio] so

as to permit the unsafe unloading of equipment and thus causing injury to the

Plaintiff;

k. Allowed the Genie lift to be unloaded in a manner so as to create an

unreasonably dangerous and hazardous condition when CSS [Audio] knew or

should have reasonably known that unloading of the Genie lift posed an

unreasonable risk of harm to [civic center] employees, including the Plaintiff;

l. Failed to adequately and properly supervise its agents, employees, and servants

so as to ensure the safe unloading of equipment from the aforementioned trailer;

and

m. Was otherwise careless and/or negligent.”

Plaintiff further alleged, as a proximate result of one or more of defendants’ actions, she was

“permanently injured” and “suffered great pain and anguish, and disability both in mind and

body.”

¶5 Defendants filed motions for summary judgment in March 2022, asserting no

genuine issue of material fact existed on the element of duty and they were entitled to judgment

in their favor. In support of their motions, defendants attached an accompanying memorandum

of law as well as the discovery depositions of several civic center employees, including plaintiff,

-3- William Kenney, Thomas Chladny, Jeff Wald, and Dan Evans; Premiere’s assistant director of

audio and visual, Michael Reid; and CSS Audio employees, Daniel Grimm and David Batton.

¶6 In her deposition, plaintiff testified she started working as a stagehand for the

civic center in 2007. As a stagehand, plaintiff’s duties were to “to unload equipment out of

semitrucks, trailers, whatever the show shows up with” and “take the cases or equipment ***

down the ramp and into wherever it’s going.” Plaintiff further testified she received “[m]ostly

on-the-job training,” stating, “there’s not really much training for pushing-a-case-off-a-truck

kind of thing.”

¶7 On the date of the accident, plaintiff was sent to “the loading dock *** facing

Kumpf Street” to unload equipment for an event hosted by the civic center. The loading dock

was clear of debris. The configuration of Premiere’s trailer was “how it’s supposed to be,” with

its ramp “folded down[,] and then there was a little metal plate that folded down that touched the

concrete.” Plaintiff explained she had, on numerous occasions, unloaded trailers with similar

configurations over the course of her employment. She also had no concerns regarding the

ramp’s stability or safety as she unloaded the trailer.

¶8 Plaintiff testified the Genie lift was the final piece of equipment on Premiere’s

trailer. Although plaintiff received no instruction on how to move the lift on the date of the

accident, she testified she safely unloaded similar lifts in the past and understood them to be

“very top heavy and very tippy.” When asked to describe how the accident occurred, plaintiff

stated:

“I went onto the trailer to get the Genie Lift. Jeff Wald was there. He grabbed one

end. I grabbed the other end. We were moving it towards the front of the trailer. I

-4- was guiding it down the ramp, he was guiding it from behind, and as we got to the

bottom, the Genie Lift started falling and landed on me.”

In plaintiff’s opinion, the unevenness of the ramp on the concrete caused the lift to fall as she and

Wald unloaded it from the trailer.

¶9 Michael Reid, Premiere’s assistant director of audio and visual, testified CSS

Audio hired Premiere to provide video equipment “for a show in the upstairs of the ballroom at

the [Peoria] Civic Center” on February 1, 2018. In addition to the equipment being delivered for

the event, Reid testified Premiere brought two Genie lifts to be returned to CSS Audio. Reid

explained, “typically *** if we have a piece of equipment of theirs or they have something of

ours[,] if we don’t need it until we meet up in a show at some point[,] we usually bring it back

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Eidson v. Audrey's C T L, Inc.
621 N.E.2d 921 (Appellate Court of Illinois, 1993)
Adams v. Northern Illinois Gas Co.
809 N.E.2d 1248 (Illinois Supreme Court, 2004)
Espinoza v. Elgin, Joliet & Eastern Railway Co.
649 N.E.2d 1323 (Illinois Supreme Court, 1995)
Coole v. Central Area Recycling
893 N.E.2d 303 (Appellate Court of Illinois, 2008)
Valfer v. Evanston Northwestern Healthcare
2016 IL 119220 (Illinois Supreme Court, 2016)
Beaman v. Freesmeyer
2019 IL 122654 (Illinois Supreme Court, 2019)
Hansen v. Ruby Construction Co.
508 N.E.2d 301 (Appellate Court of Illinois, 1987)
Mayfield Cooper Brotze v. City of Carlinville
2021 IL App (4th) 200369 (Appellate Court of Illinois, 2021)

Cite This Page — Counsel Stack

Bluebook (online)
2023 IL App (4th) 220479-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/short-v-css-audio-inc-illappct-2023.