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constructive notice

Plaintiff Irina Galperin suffered an injury when she fell at Macy’s, located in the Garden State Plaza Shopping Center in Paramus, New Jersey, upon stepping from a tile walkway to a carpeted area.  While she initially claimed that she fell due to liquid on the floor, she later claimed that she fell when her foot got caught on the edge of the carpet which bordered the tile walkway inside the Macy’s store.  The issue in Galperin v. Macy’s, 2023 N.J. Super. Unpub. LEXIS 589 (App. Div. Apr. 19, 2023) was whether plaintiff would be able to maintain a negligence claim against Macy’s in light of her failure to identify the exact dangerous condition which caused her fall and the lack of an expert to identify a breach of duty in the design of the flooring.

In answers to Interrogatories, plaintiff certified “she was caused to slip and fall due to a dangerous condition, namely liquid on the floor.”  However, in her deposition, she disavowed this response and stated that she was unable to identify anything on the floor that caused or contributed to the fall.  She submitted an amended Interrogatory answer, stating that when she fell, the front of her right foot got caught on the edge of the carpet which bordered the tile walkway.  Further, she testified at her deposition that the incident occurred after she stepped off the escalator and walked toward the store’s exit.  She stated that there were too many people in the aisle and, while trying to go around the customers, she fell on the border of tile and carpet and struck a table display with a metal frame.  As for the cause of her fall, she simply stated it was the border between the tile and carpet. 

At the trial court level, Macy’s filed a motion for a summary judgment dismissal, arguing that plaintiff failed to identify a dangerous condition that caused her accident and she did not establish Macy’s possessed actual or constructive notice of any such condition.  Further, to the extent that plaintiff was maintaining that the purported height differential constituted a hazardous condition, Macy’s argued that “any claim was beyond the ken of the average juror thereby requiring expert testimony, which she failed to provide.”

The trial court agreed with Macy’s that plaintiff had failed to offer any proof of a dangerous condition.  The court rejected plaintiff’s argument that “the mere existence of a transition from tile to a carpet, without even some kind of torn or ripped carpet, broken tiles, or misleveled surface, constituted a dangerous condition.”  Further, plaintiff had failed to submit any factual or expert proofs that the flooring violated some code or regulation or standard that a reasonably prudent business owner would meet.  The court agreed that a claim that the border between the tile and the carpet created a defect required expert testimony. 

Hence, the trial court granted the summary judgment as to Macy’s.

Upon appeal, the plaintiff made the same arguments to the Appellate Division that were made to the trial court.  However, the Appellate Division rejected those arguments and agreed with the trial court and noted that the “mere showing of an accident causing the injuries sued upon is not alone sufficient to authorize an inference of negligence.”  The Court noted that the plaintiff had failed to identify anything related to the tile or carpet that caused her to fall.  The vague statements that her foot caught on the edge of the carpet and something between the tiles and the carpet caused her to fall were found to be insufficient to establish a dangerous condition.  Further, the Appellate Division agreed that an expert would be necessary to establish the existence of a dangerous condition that the transition area was dangerous due to a design or installation defect.

Thus, the Appellate Division affirmed the trial court decision, stating that “[i]n light of plaintiff’s inability to identify the circumstances of her fall, expert testimony was necessary to establish the area where she fell was in some manner dangerous, if for no other reason than to exclude other potential causes of the accident and avoid pure speculation by the factfinder.” 

Plaintiff Talia Pena claimed that, while shopping in a store, she was struck by an unidentified customer operating a motorized shopping cart. While bending over to smell body sprays on a lower shelf near the self-checkout lanes, an unidentified female customer drove a motorized cart into her. The woman did not see Plaintiff because her cart was stacked so high with paper products, they blocked the woman’s vision. The issue in the District Court of New Jersey Pena case (2022 U.S. Dist. LEXIS 215009 Nov. 29, 2022), was whether the mode of operation rule would apply to this accident, which would obviate the need for the Plaintiff to prove that the store had actual or constructive notice of the alleged dangerous condition.

The defendant store filed for a summary judgment, arguing that the mode of operation rule did not apply and, because Plaintiff could not demonstrate actual or constructive notice of the “dangerous condition,” it should be granted a summary judgment dismissal.

The District Court noted the general duty under New Jersey law that “business owners owe to invitees a duty of reasonable care to provide a safe environment for doing that which is within the scope of the invitation.”  That duty would include an obligation “to maintain the premises in safe condition, and to avoid creating conditions that would render the premises unsafe.” The plaintiff must prove that “the defendant had actual or constructive knowledge of the dangerous condition that caused the accident.”

The District Court also noted that “a plaintiff need not prove actual or constructive notice under the ‘mode of operation’ rule, which applies ‘when a substantial risk of injury is inherent in a business operator’s method of doing business.’” For that rule to apply, “the plaintiff must show there was a ‘reasonable probability’ that the dangerous condition would occur ‘as the result of the nature of the business, the property’s condition, or a demonstrable pattern of conduct or incidents.’”

The Court rejected the Plaintiff’s argument that the mode of operation rule should apply to the use of a motorized cart. Merely providing shopping carts as a self-service equipment “does not alone increase the risk of a dangerous condition to warrant application of the mode of operation rule.” The District Court found that the rule would not apply because Plaintiff was unable to produce any evidence to support her position that supplying motorized carts, as opposed to non-motorized shopping carts, “is an aspect of the store’s self-service operation that creates a substantial risk of injury.”

Further, the Plaintiff presented no evidence that the store had actual notice of the alleged dangerous condition. As for constructive notice, Plaintiff had produced no evidence of how long this unidentified customer had over stacked her cart before Plaintiff’s accident. Thus, without the application of the mode of operation rule, and Plaintiff being unable to prove that the store had actual or constructive notice of the alleged hazard, the District Court granted the defendant’s motion for summary judgment, dismissing the lawsuit.

Plaintiff Luz Cruz (“Cruz”) tripped and fell in a pothole when crossing River Avenue in Camden, New Jersey. She broke her fifth metatarsal of her left foot and sued the County of Camden for her injuries. In Cruz v. Camden County, 2019 N.J. Super. Unpub. LEXIS 385 (App. Div. Feb. 19, 2019), one of the issues was whether the County had prior notice of the pothole.

Cruz and her friend drove a U-Haul truck to pick up a couch in an apartment on River Avenue, a County owned road. They parked the truck across the street from the apartment. They did not see a pothole while walking to the apartment. As they were carrying the couch to the truck, Cruz stepped into the pothole in the middle of the road and fell. About two months after the accident, plaintiff’s expert measured the pothole as about 18 inches in length, 6 inches wide, and 3 inches deep.

The County had no prior notice of this pothole’s existence. The County’s Department of Public Works (“DPW”) employees are tasked with looking for potholes and repair them upon their discovery. In addition, the County has a dedicated phone line and email address for complaints as to potholes or other road problems. Also, police, fire, and public safety personnel will report road problems. However, no complaints had been called in as to this particular pothole or on this block of River Avenue in the 10 years before the accident.

As for constructive notice, plaintiff was unable to establish how long the pothole had been present. Cruz had been there the year before at the same address and did not notice the pothole. Plaintiff retained an expert who did not determine or estimate when the pothole had formed.

The County filed a motion for summary judgment, arguing that the plaintiff had failed to show that the County had actual or constructive notice of the pothole, as required under the Tort Claims Act to prove a claim against a public entity for a dangerous condition. The trial court agreed and granted the motion, finding that the plaintiff was unable to prove any time frame for the pothole or that the pothole was “of such an obvious nature that the public entity, in exercise of due care, should have discovered the condition and its dangerous character.”

The plaintiff appealed to the Appellate Division, arguing that the County had actual or constructive notice of the pothole and failed to repair it and that the County’s failure to maintain a major County road was palpably unreasonable. The Appellate Division rejected these arguments and upheld the trial court’s decision.

The Appellate Division noted that public entity liability is restricted under the Tort Claims Act. For liability to attach for an injury caused by a dangerous condition, a plaintiff must establish that a public entity “had actual or constructive notice of the dangerous condition” in “a sufficient time prior to the injury to have taken measures to protect against the dangerous condition.”

The Court agreed with the trial court that there was no actual notice. The question was whether the plaintiff had proven that the County had constructive notice of the pothole. To prove constructive notice, the plaintiff must establish “that the condition existed for such time that the [County], in exercising due care, should have discovered the condition and its dangerous condition.” The Appellate Division found that was no evidence of how long the pothole existed before the accident. Hence, the plaintiff could not prove constructive notice either. Without such notice, the Court found that the plaintiff’s claim fails.

The Appellate Division also found that the County’s inaction in repairing River Avenue was not palpably unreasonable. The plaintiff failed to show that it was not palpably unreasonable for the County to fail to fix a pothole that was harmless for a vehicle to pass over to prevent a pedestrian to trip over in a portion of the road that was not a designated crosswalk.

This case is illustrative of the difficulty that plaintiffs face in pursuing pothole claims against public entities. Because potholes can pop up in a day, depending on weather conditions, unless the public entity has actual notice of the pothole, it can be very difficult for a plaintiff to prove constructive notice.

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Betsy G. Ramos, Esq. is a member of the firm’s Executive Committee and Co-Chair of the Litigation Group. She is an experienced litigator with over 25 years’ experience handling diverse matters. Her practice areas include tort defense, insurance coverage, Tort Claims Act and civil rights defense, business litigation, employment litigation, construction litigation, estate litigation and general litigation.

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