Williamson v. Evans Nails & Spa Corp.

2023 IL App (1st) 220084, 220 N.E.3d 1231, 468 Ill. Dec. 452
CourtAppellate Court of Illinois
DecidedMarch 3, 2023
Docket1-22-0084
StatusPublished
Cited by2 cases

This text of 2023 IL App (1st) 220084 (Williamson v. Evans Nails & Spa Corp.) 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
Williamson v. Evans Nails & Spa Corp., 2023 IL App (1st) 220084, 220 N.E.3d 1231, 468 Ill. Dec. 452 (Ill. Ct. App. 2023).

Opinion

2023 IL App (1st) 220084 No. 1-22-0084 Opinion filed March 3, 2023 FIFTH DIVISION

IN THE APPELLATE COURT OF ILLINOIS FIRST JUDICIAL DISTRICT

MARIE WILLIAMSON, ) Appeal from the ) Circuit Court of Plaintiff-Appellant, ) Cook County. ) v. ) No. 2021 L 1414 ) EVANS NAILS & SPA CORPORATION, ) Honorable ) John H. Ehrlich Defendant-Appellee. ) Judge presiding.

JUSTICE MITCHELL delivered the judgment of the court, with opinion. Justice Connors 1 and Justice Lyle concurred in the judgment and opinion.

OPINION

¶1 Plaintiff Marie Williamson appeals a grant of summary judgment in favor of Defendant

Evans Nails & Spa Corporation in this slip-and-fall case. The issue presented is whether the circuit

court erred in entering judgment as a matter of law because plaintiff had come forward with

sufficient evidence to create a fact question as to proximate cause. For the following reasons, we

reverse and remand.

¶2 Williamson went to Evans Nails & Spa Corporation’s salon in Evanston, Illinois, for a

manicure and pedicure. The pedicure chair was on a raised platform and connected to a tub

containing water. After receiving a pedicure, a salon worker gave Williamson flip-flops and

1 Justice Connors participated in this appeal and the decision to publish, but she has since retired. See Proctor v. Upjohn Co., 175 Ill. 2d 394, 396 (1997). No. 1-22-0084

directed her toward the manicure station. While stepping down from the pedicure chair,

Williamson fell and broke her leg. A security camera captured the entire incident.

¶3 Williamson filed a complaint against Evans Nails. She alleged Evans Nails was negligent

by causing the steps and floor to become slippery, failing to assist Williamson in descending from

the elevated chair, and failing to warn Williamson of the slippery steps and floor.

¶4 After limited discovery, Evans Nails moved for summary judgment bringing a Celotex

motion 2 predicated on a supposed absence of evidence on proximate cause and on Williamson’s

inability to identify where or on what she slipped. The circuit court granted the motion. 735 ILCS

5/2-1005 (West 2020). The court reasoned that the video was insufficient evidence of proximate

cause because the resolution was too low to make out any slip-inducing foreign substance. The

court concluded that Williamson’s inability to state precisely where she slipped made it impossible

to determine whether following an ordinance or industry standards would have changed the

outcome. Williamson took this timely appeal. Ill. S. Ct. R. 303 (eff. July 1, 2017).

¶5 Williamson argues that the trial court erred in granting summary judgment because there

was evidence that (1) Evans Nails violated a safety ordinance that required handrails; and (2) Evans

Nails had failed to install slip-resistant flooring around the pedicure station. Evans Nails maintains

the trial court did not err because Williamson failed to establish proximate cause. Evans Nails

contends that a violation of statute was not alleged in the complaint and that Williamson’s expert

affidavit is inadequate. We review a grant of summary judgment de novo. Cohen v. Chicago Park

District, 2017 IL 121800, ¶ 17.

2 A “Celotex motion” is a summary judgment motion made by a party who does not have the burden of proof and which asserts that the nonmovant cannot prove an element of its claim. See Celotex v. Catrett, 477 U.S. 317, 324-25 (1986).

-2- No. 1-22-0084

¶6 This slip-and-fall case presents an ever increasingly common occurrence: it was captured

entirely on a video surveillance camera. And pictures do not lie. This visual evidence takes on a

singular importance in this case because it readily belies many of the defense’s arguments in favor

of summary judgment. Consider this still image taken from the surveillance footage of record

showing the moment when Williamson begins to fall:

The image shows Williamson reaching out to the salon technician with her left hand and grabbing

the adjacent cart with her right hand as her right leg bends and her left leg slips forward. In the

fractional second before, Williamson is plainly stepping down from the pedicure platform.

-3- No. 1-22-0084

¶7 The video shows the location, circumstance, and biomechanics of Williamson’s fall, and it

became a basis for Scott Leopold’s expert opinion. An engineer by training with significant

experience investigating slips and falls, Leopold opined that the pedicure platform was

unreasonably dangerous because it lacked a handrail in violation of a local Evanston ordinance. A

violation of an ordinance designed to protect human life is prima facie evidence of negligence.

Kalata v. Anheuser-Busch Cos., 144 Ill. 2d 425, 434 (1991). A plaintiff injured by such a violation

must show (1) she belongs to the class of persons the ordinance was designed to protect; (2) it is

the type of injury the ordinance was designed to protect; and (3) the violation proximately caused

the injury. McCarthy v. Kunicki, 355 Ill. App. 3d 957, 970 (2005). The Evanston ordinance

expressly provides that it is a public safety measure applicable to commercial buildings, and it is

self-evident that Williamson, as a patron of an Evanston business, is within the class of persons

whom the ordinance is intended to protect.

¶8 Based on Williamson’s deposition testimony and the video, there was direct evidence in

the record to support an inference that the absence of a handrail proximately caused Williamson’s

injury. Williamson testified that when she first began to slip, the salon technician “put her hand

out. I was going to grab her hand and that’s when I slipped.” In Kalata, 144 Ill. 2d at 434, the

Supreme Court considered a Chicago ordinance that required handrails on both sides of stairways.

There, the plaintiff testified that he slipped when he was stepping to the left side of the stairway to

use the handrail on that side. Id. at 436. The court deemed the plaintiff’s testimony sufficient to

show that the absence of a handrail on the right side of the stairway proximately caused his injury.

Id. at 438.

-4- No. 1-22-0084

¶9 In McCarthy, 355 Ill. App. 3d at 971, another case of a handrail ordinance violation, the

plaintiff’s testimony that she slapped her hand against the wall trying to catch herself created an

inference that the absence of a handrail proximately caused her injury. The McCarthy court

summarized the rule to be distilled from Illinois cases: “[W]here plaintiff’s fall down a stairway

was potentially caused by the absence of handrails, the issue of proximate cause has been held a

question of fact for the jury. [Citations.]” Id.

¶ 10 Williamson also alleged that Evans Nails was negligent by not providing slip-resistant

flooring on the stair or salon floor. A claim for negligence requires the plaintiff to show (1) a duty

was owed by the defendant, (2) defendant breached that duty, and (3) the breach was the proximate

cause of the plaintiff’s injuries. Monson v. City of Danville, 2018 IL 122486, ¶ 23. A photograph

of the pedicure chair showed that there was a slip-resistant mat to the side of the chair on the

elevated platform, but there was no such material on the step or floor. Further, plaintiff’s expert

opined that the Evanston ordinance and industry standards required slip-resistant flooring or mats

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Bluebook (online)
2023 IL App (1st) 220084, 220 N.E.3d 1231, 468 Ill. Dec. 452, Counsel Stack Legal Research, https://law.counselstack.com/opinion/williamson-v-evans-nails-spa-corp-illappct-2023.