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Aupperlee v. Restaurant Depot, LLC

Citation: 2019 NY Slip Op 8548Docket: 2016-13369

Court: Appellate Division of the Supreme Court of the State of New York; November 26, 2019; New York; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

In Aupperlee v. Restaurant Depot, LLC, the legal dispute arose from a personal injury incident involving a customer, Patricia Novak, who was injured by another customer's U-Boat shopping cart at a Restaurant Depot location. Initially, the jury found Restaurant Depot 70% at fault and awarded damages to Novak. However, Restaurant Depot appealed, contending it had no duty to control the conduct of the customer responsible for the injury. The Appellate Division of the New York Supreme Court overturned the lower court's ruling, granting summary judgment in favor of Restaurant Depot and dismissing the complaint. The court elaborated that while store owners are obligated to ensure a safe environment, their duty to control third-party conduct is confined to situations where they could reasonably foresee and have the opportunity to intervene. In this instance, the court concluded that Restaurant Depot had neither the duty to supervise the customer's actions nor to monitor how items were loaded into the shopping carts. Thus, the case underscores the constraints on property owners' liability regarding customer actions, emphasizing the necessity of a demonstrable duty of care.

Legal Issues Addressed

Duty of Care for Store Owners

Application: The court determined that while store owners have a duty to maintain safe premises, this duty does not extend to controlling the actions of customers unless there is an opportunity and awareness to do so.

Reasoning: The court clarified that while store owners have a duty to maintain safe premises and may have a duty to control third-party conduct, this duty is limited to situations where they have the opportunity and awareness to exercise such control.

Limitations of Property Owner's Liability

Application: In this case, Restaurant Depot was not found liable for the actions of a customer because the store did not have a duty to control the customer's conduct under the circumstances.

Reasoning: In this case, the court found that Restaurant Depot did not have a duty to monitor the height of items loaded in the shopping carts or to control the actions of its customers.

Summary Judgment in Personal Injury Cases

Application: The Appellate Division granted summary judgment to Restaurant Depot, dismissing the complaint due to the absence of a duty of care to control the customer's conduct.

Reasoning: The Appellate Division of the New York Supreme Court reversed the lower court's decision, granting Restaurant Depot's motion for summary judgment and dismissing the complaint against it.