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Coleman v. Wal-Mart Stores, Inc.

Citations: 802 So. 2d 716; 99 La.App. 4 Cir. 2274; 2001 La. App. LEXIS 2715; 2001 WL 1464230Docket: No. 99-CA-2274

Court: Louisiana Court of Appeal; August 29, 2001; Louisiana; State Appellate Court

Narrative Opinion Summary

In this case, the plaintiff appealed a trial court judgment which held her and Wal-Mart Stores, Inc. equally liable for injuries she sustained when a bicycle fell from a shopping cart in a Wal-Mart store. The jury awarded her $2,500 in general damages and $1,045 in past medical expenses, but the trial court reduced these by 50% due to shared fault. However, the plaintiff argued against the attribution of fault and the alleged inadequacy of the damages awarded. Evidence at trial included testimony from Wal-Mart’s assistant manager and the plaintiff, indicating that the plaintiff was not at fault for the incident. The appellate court found that the jury erred in attributing any fault to the plaintiff, amending the judgment to hold Wal-Mart 100% liable. The court also considered the plaintiff's pre-existing shoulder condition, aggravated by the incident, in affirming the general damages award. Ultimately, the appellate court amended the judgment to assign full fault to Wal-Mart, while upholding the amount of damages awarded by the trial court.

Legal Issues Addressed

Assessment of General Damages

Application: The court upheld the trial court's award of $2,500 in general damages despite the plaintiff's contention of insufficiency, citing the broad discretion of the trier of fact.

Reasoning: The court referenced a precedent affirming the broad discretion of the trier of fact in awarding general damages, and based on trial evidence regarding the plaintiff's injuries, it upheld the trial court's $2,500 general damages award.

Comparative Fault under Louisiana Law

Application: The trial court initially found both parties equally at fault, but the appellate court amended the judgment to assign 100% fault to Wal-Mart based on the lack of evidence implicating the plaintiff.

Reasoning: The record showed no evidence implicating her or another customer in causing the bicycle to fall, leading to the conclusion that the jury erred in attributing any fault to the plaintiff.

Liability under La. R.S. 9:2800.6(A)

Application: The plaintiff needed to demonstrate that she did not cause the bicycle to fall, that another customer did not cause it, and that Wal-Mart’s negligence was a contributing factor, which was successfully demonstrated.

Reasoning: To succeed in her claim under La. R.S. 9:2800.6(A), the plaintiff needed to demonstrate that she did not cause the bicycle to fall, that another customer did not cause it, and that Wal-Mart’s negligence was a contributing factor.

Pre-existing Condition Consideration

Application: The court considered the plaintiff's pre-existing shoulder condition and its aggravation due to the accident when assessing damages and fault.

Reasoning: Dr. Marrero stated that the December 1995 accident worsened the plaintiff's pre-existing shoulder condition.