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Fenster v. Publix Supermarkets, Inc.

Citations: 785 So. 2d 737; 2001 WL 575095Docket: 4D00-2145

Court: District Court of Appeal of Florida; May 30, 2001; Florida; State Appellate Court

Narrative Opinion Summary

In this negligence case, the appellant, a customer, sued the appellee, a supermarket, after tripping over a stock cart allegedly left in a hazardous position by an employee. The appellant claimed that the supermarket was negligent in placing the cart, failing to adequately warn patrons, and not moving the cart out of her path. The incident took place when the appellant, assuming the cart would be completely moved by a stock clerk, turned without looking and fell. The supermarket sought summary judgment, arguing that the appellant's injuries resulted solely from her negligence, as no dangerous condition existed. The trial court initially granted summary judgment in favor of the supermarket. However, upon review, the appeals court reversed this decision, highlighting the existence of genuine issues of material fact regarding the supermarket's alleged negligence and the appellant's comparative negligence. The appeals court underscored the cautious nature required in granting summary judgments in negligence cases and remanded the case for further proceedings, allowing a jury to resolve the factual disputes.

Legal Issues Addressed

Comparative Negligence

Application: The court noted that a plaintiff's knowledge of a dangerous condition does not bar recovery but may affect comparative negligence, requiring the issue to be assessed by a jury.

Reasoning: A plaintiff's awareness of a dangerous condition does not eliminate a defendant's liability but raises comparative negligence, preventing summary judgment.

Duty of Property Owners to Invitees

Application: The case affirms that property owners owe a duty to maintain safe premises and warn of concealed dangers, even if the plaintiff is aware of the danger.

Reasoning: Property owners owe invitees a duty to maintain safe premises and warn of concealed dangers. A plaintiff's awareness of a dangerous condition does not eliminate a defendant's liability but raises comparative negligence, preventing summary judgment.

Summary Judgment in Negligence Cases

Application: The court emphasized the cautious approach required in granting summary judgments in negligence cases, highlighting that disputed issues warrant a jury trial.

Reasoning: Summary judgments in negligence cases are to be granted cautiously, requiring the moving party to conclusively demonstrate the absence of genuine material fact issues.