Walgreens Co. v. Maria Victoria Chaux

CourtDistrict Court of Appeal of Florida
DecidedJanuary 14, 2026
Docket3D2024-0288
StatusPublished

This text of Walgreens Co. v. Maria Victoria Chaux (Walgreens Co. v. Maria Victoria Chaux) is published on Counsel Stack Legal Research, covering District Court of Appeal of Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Walgreens Co. v. Maria Victoria Chaux, (Fla. Ct. App. 2026).

Opinion

Third District Court of Appeal State of Florida

Opinion filed January 14, 2026. Not final until disposition of timely filed motion for rehearing.

________________

Nos. 3D24-0288 & 3D24-0761 Lower Tribunal No. 21-23442-CA-01 ________________

Walgreens Co., Appellant,

vs.

Maria Victoria Chaux, Appellee.

An Appeal from the Circuit Court for Miami-Dade County, William Thomas, Judge.

GrayRobinson, P.A., and Jack R. Reiter and Sydney Feldman D'Angelo, for appellant.

The Sanchez Law Group and Gabriel Sanchez; Keith Chasin P.A., and Keith Chasin; Burlington & Rockenbach, P.A., and Bard D. Rockenbach and Nichole J. Segal (West Palm Beach), for appellee.

Before LOGUE, GORDO and LOBREE, JJ.

LOBREE, J.

Walgreens Co. (“Walgreens”) appeals a final judgment resulting from a jury verdict in favor of Maria Victoria Chaux (“Chaux”) and the denial of its

motion for a new trial in this slip-and-fall case. Walgreens also appeals a

final judgment of attorney’s fees and costs. 1 Raising multiple grounds of trial

court error, Walgreens claims it is entitled to a new trial. We agree with

Walgreens on two of its points, and reverse and remand for a new trial. 2 We

also reverse the final judgment of attorney’s fees and costs.

BACKGROUND

While in the checkout lane of her neighborhood Walgreens, Chaux fell

to the floor. A Walgreen’s employee who heard Chaux fall found her laying

on her back and unconscious. The store manager, Jose Fundora, called

911, and Chaux was transported to the hospital. As a result of the fall, Chaux

suffered a brain injury and was in the hospital for over three months. Chaux

subsequently sued Walgreens for negligence. After a five-day trial, the jury

returned a verdict in Chaux’s favor and awarded damages of $5,547,733.

The trial court entered final judgment in accordance with the jury’s verdict

1 Walgreens separately appealed the final judgment of attorney’s fees and costs in case no. 3D24-0761. We consolidated the two appeals for all appellate purposes under case no. 3D24-0288. 2 “We need not address every argument raised by [Walgreens] on appeal in order to reverse for a new trial, and nothing in this opinion should be construed as a determination on the merits of the unreached issues.” Johns Hopkins All Child’s Hosp., Inc. v. Kowalski, No. 2D2024-0382, 2025 WL 3019111, at *17 n.22 (Fla. 2d DCA Oct. 29, 2025)

2 and reserved jurisdiction to determine entitlement to attorney’s fees, if any,

and costs. Thereafter, Walgreens moved for a new trial, which the trial court

denied. The following facts are pertinent to the specific issues addressed on

appeal.

I. Jury Instruction Regarding Spoliation of Evidence

Five days after Chaux fell, her counsel sent a letter to Fundora

requesting that Walgreens preserve any surveillance video in or around the

premises and any surveillance video of the incident, including three hours

before and after the incident. That same day, Chaux’s counsel went to the

Walgreens where the incident occurred and asked to see video from a

security camera located above the cash register. Fundora told Chaux’s

counsel that to see the video, he needed to go through their claims

administrator, Sedgwick Claims Management Services, Inc. (“Sedgwick”).

Chaux’s counsel then demanded that Sedgwick preserve and provide the

surveillance video. Sedgwick replied that “the area of the incident within the

store was not captured on video,” and maintained that “[b]ased on facts

known, Ms. Chaux experienced a seizure and therefore was not injured as a

result of any liability on the store.”

Chaux subsequently filed an amended complaint for negligence

against Walgreens, alleging that she “slipped and fell injuring her head” on

3 Walgreens’ premises because it “created a dangerous condition by allowing

its floor to become inherently slippery and/or allowing a foreign substance to

remain on the floor which caused the floor to be slippery.” Chaux further

alleged that Walgreens knew or should have known of the dangerous

condition, failed to timely maintain the floor, and failed to warn of the

dangerous condition. Chaux also alleged that she had timely demanded that

Walgreens preserve and produce CCTV video footage from at least one hour

before the fall and thirty minutes after, but Walgreens had not yet provided

any CCTV footage. Chaux alleged that if Walgreens failed to preserve and

produce the CCTV footage for this area, she would be “entitled to the

imposition of a negative inference.” Shortly after Chaux filed her amended

complaint, in response to Chaux’s counsel’s inquiry, Walgreen’s counsel

stated that the incident was not captured on video and “there is no store

video.”

Prior to trial, Chaux moved for spoliation sanctions, arguing that “a

negative presumption be given to the jury” for Walgreens’ failure to preserve

the CCTV video footage. The trial court held an evidentiary hearing on

Chaux’s motion. At the conclusion of hearing, the trial court stated that “I

think some form of an adverse inference instruction is appropriate.”

Thereafter, the trial court entered its sanctions order, finding that Walgreens

4 had a duty to preserve the CCTV video and that its failure to do so hindered

Chaux’s ability to establish a prima facie case. The sanctions order stated

that the trial “has not yet determined the appropriate [jury] instruction.”

On the first day of trial, Chaux raised the issue of the jury instruction

arguing that because the trial court found that Walgreens had a duty to

preserve the video and its failure to do so hindered Chaux’s ability to

establish her case, she was entitled to a “presumption of negligence

instruction” under Florida Standard Jury Instruction 301.11(b). Walgreens

countered that “an inference instruction,” set forth in Florida Standard Jury

Instruction 301.11(a), was appropriate. After reading 301.11(a), the trial

court stated that “in light of where we are in this case, I think that is the more

appropriate instruction.” The trial court added that it was “more than

comfortable saying that there is an adverse inference that is created, that

had that video been available, it would have been adverse to the position

being taken by Walgreens,” but “I am not telling the jurors that you - - I’m not

giving a presumption that you’ve proven your case.”

At the charge conference, Walgreens objected to the trial court’s

proposed jury instruction 3 and requested standard jury instruction 301.11(a).

3 The prior day, after the parties rested, the trial court proposed the following jury instruction on spoliation:

5 The trial court stated that because of Walgreens’ objection, it had no choice

but to give the instruction requested by Chaux. Walgreens objected, arguing

that “throughout the course of this case it was always going to be the

plaintiff’s burden.” Ultimately, the trial court instructed the jury as follows:

The Court has determined that Walgreens had a duty to maintain the security video evidence. The Court has further determined, and you must accept as true, that Walgreens failed to maintain the security video evidence in that the security video evidence was lost, destroyed, concealed or otherwise made unavailable to the plaintiff.

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