The Estate of Joan Berkeley v. Amc Entertainment Holdings, Inc.

CourtNew Jersey Superior Court Appellate Division
DecidedApril 16, 2025
DocketA-0806-23
StatusUnpublished

This text of The Estate of Joan Berkeley v. Amc Entertainment Holdings, Inc. (The Estate of Joan Berkeley v. Amc Entertainment Holdings, Inc.) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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The Estate of Joan Berkeley v. Amc Entertainment Holdings, Inc., (N.J. Ct. App. 2025).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited. R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-0806-23

THE ESTATE OF JOAN BERKELEY, deceased,

Plaintiff-Appellant,

v.

AMC ENTERTAINMENT HOLDINGS, INC., AMC THEATRES, AMC LOEWS, and AMC LOEWS, BRICK PLAZA 10,

Defendants-Respondents. ___________________________

Argued March 27, 2025 – Decided April 16, 2025

Before Judges Mawla and Natali.

On appeal from the Superior Court of New Jersey, Law Division, Middlesex County, Docket No. L-0778-17.

Charles C. Berkeley argued the cause for appellant.

Catherine De Angelis argued the cause for respondents (Weber Gallagher Simpson Stapleton Fires & Newby LLP, attorneys; Catherine De Angelis and Rafael A. Soto, on the brief). PER CURIAM

After a jury returned a no cause of action verdict with respect to plaintiff's

negligence-based complaint, plaintiff filed this appeal challenging a November

30, 2018 order that denied its motion to amend the complaint to include a count

for fraudulent concealment, a related request for an adverse spoliation inference

charge at trial, and a January 11, 2019 order that denied plaintiff's motion for

reconsideration. Having considered the record in the context of our standards

of review and the substantive legal principles, we affirm.

I.

On August 13, 2016, Joan Berkeley 1 tripped and fell at an AMC Loews

movie theater in Brick causing her to sustain "severe and permanent injuries."

According to the guest incident report authored by her son, Charles, 2 who

witnessed the incident, his mother "fell walking down [the] left side of theater

five at [the] first step down before the movie began at approximately 8[:]00

p[.]m[.,]" sustaining an "injury to [her] right eye and right shoulder."

1 Plaintiff passed away during the litigation and is now represented by her estate. 2 Because Joan and her son share a common surname, we refer to them by their first names and intend no disrespect. A-0806-23 2 According to the AMC incident report authored by its employee Brianne

Taylor Owen, an "elderly guest came out with her son after [the movie] to let

[Owen] know that while walking on the left side of the auditorium to a seat

during the trailers[,] . . . she had fallen down the step and onto her face." After

conducting an inspection of the area where Joan fell, Owen checked the lights

on the steps and stated they were all "fully lit and the lights in the auditorium

itself were at trailer level and in working order as well."

Less than three weeks later, on September 1, 2016, Joan's then attorney

sent AMC a letter alleging her injuries were caused by defendants' negligence.

Specifically, counsel maintained

the incident occurred as a result of the improper actions of the theater in question relative to its design, maintenance[,] and control at the time the incident occurred. Despite the fact that there was no movie showing . . ., the theater was unlit with the exception of inadequate lighting[,] which caused [Joan] to fall and sustain serious injuries to her right eye.

Counsel did not specifically request defendants maintain or preserve any

documents related to the incident. Approximately five months later, Joan filed

a negligence-based complaint against defendants. Defendants answered, denied

liability, and asserted various affirmative defenses.

A-0806-23 3 In response to Joan's request for admissions, defendants admitted the

playback of commercial advertisements and dimming of lights in its theaters is

automatically controlled by the Theater Management System (TMS), but denied

there existed any issue with either the automatic playback of commercial

advertisements or the lighting system. Further, in response to plaintiff's

interrogatories, defendants stated the "TMS was reviewed by AMC Brick Plaza

[Ten] theater personnel following [Joan's] alleged incident and showed that all

cues played; TMS does not retain information dating as far back as August 13,

2016."

Deposition discovery provided further details about the incident. With

respect to the lighting in the theater at the time of the incident, Charles testified

"[t]he only lights [he] noticed were the first place [he] looked to sit was the

balcony and [he] saw blue lights [he] guess[ed] at seat level[,] which . . . were

eye level as [he] walked in. It was dark. And dim floor lighting." Specifically,

Charles noticed yellow lights on either side of the aisle and lights on the stairs.

Joan testified the theater was "pitch black. It[ was] like walking into a

closet. There [were] no lights overhead at all, nothing on the screen." She

further explained, however, while walking through the theater she "saw little

blue lights . . . and there was . . . a glow on the floor[,] which were more lights."

A-0806-23 4 Kristen Puff, a part-time AMC employee who was responsible for

"ushering, concession, box office sales, [and] customer service" at the time of

the incident, testified she would receive complaints about lights in the theater

being off when they should be on approximately "once or twice a month." Owen

similarly testified at her deposition there were times when the ceiling lights

remained off when they were supposed to be on due to a "cue issue."

With respect to the TMS, Hemil Patel, an AMC usher, explained the TMS

generates "automated errors from the projectors. So[,] they come straight to the

. . . error section which is an error log. . . . There[ are] various errors that

happen. It could range from a show is not playable . . . [to] some sort of

disconnect." Patel further testified, however, he did not know what logs the

TMS generates, and he was only familiar with general error reports.

Katherine A. Higgins, the General Manager of AMC Brick in March 2017,

who was not present at the theater during Joan's alleged incident, also testified

at her deposition about the TMS. She estimated the TMS logs are automatically

purged after three weeks.

On October 24, 2018, plaintiff filed a motion seeking leave to amend its

complaint to include a count for fraudulent concealment. Additionally, plaintiff

A-0806-23 5 sought "[t]he entry of an [o]rder providing [it] with the benefit of an adverse

inference charge at the time of the trial of this matter."

In its proposed amended complaint, plaintiff alleged the following with

respect to its allegation of fraudulent concealment: (1) defendants had a legal

obligation to disclose the TMS logs from August 13, 2016; (2) those logs were

material to plaintiff's litigation because the TMS "software failed to operate

properly in controlling the level of the ceiling lights in [a]uditorium [five],

rendering the lighting in [a]uditorium [five] inadequate and unsafe, and that this

was the proximate cause of the plaintiff's accident"; (3) plaintiff could not

reasonably obtain the TMS logs from another source; (4) defendants

"intentionally withheld or destroyed the [TMS logs] with purpose to disrupt the

underlying litigation"; and (5) plaintiff suffered damages because it had to retain

a software expert to review the TMS logs supplied by DCIP 3 but those logs,

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