Claim Based on Res Ipsa Loquitur Doctrine Rejected in Elevator Trip and Fall Case

In the case of Pyle v. Otis Elevator Co., No. 20-2393 (3d Cir. April 13, 2021) (Matey, J., Shwartz, J., Porter, J.) (Op. by Matey, J.)[Not Precedential], the Third Circuit Court of Appeals affirmed the entry of summary judgment in an elevator accident case.

According to the Opinion, an uneven elevator door allegedly caused the Plaintiff to trip and fall.    

In affirming the lower court decision, the appellate court reiterated the rule that the mere happening of an accident or injury does not establish negligence, inference or presumption of negligence, or a prima facie case of negligence. 

The court additionally ruled that a misleveled elevator, in and of itself, is not sufficient to satisfy the requirements of the res ipsa loquitur doctrine and does not necessarily imply negligent elevator maintenance. The court also found that the res ipsa loquitur doctrine did not apply here because the Plaintiff failed to rule out any non-negligent reasons for his injuries, such as losing his balance or moving too quickly.

The court also confirmed that, in an elevator accident case, the Plaintiff must show that the elevator was in a defective or dangerous condition that was discoverable by reasonable inspection.

Anyone wishing to review a copy of this Non-precedential decision may click this LINK.


I send thanks to Attorney James M. Beck of the Philadelphia law office of the Reed Smith law firm for bringing this case to my attention.