Friday, December 1, 2023

Summary Judgment Granted In Slip and Fall Case Due to Lack of Evidence of Actual or Constructive Notice of Spill

In the case of Steffe v. Wal-Mart Supercenter, No. 1:21-CV-01605 (M.D. Pa. Sept. 25, 2023 Wilson, J.), the court granted summary judgment in a slip and fall case.

In this case, the Plaintiff allegedly slipped and fell as a result of a puddle of water in the store's bathroom.

The court ruled that the Plaintiff’s slip and fall claim failed because no basis beyond speculation established that the Defendant had any notice of the allegedly dangerous condition on its property.

The court found that there was no actual evidence established in terms of a way for the alleged spill to have been caused by any of the Defendant’s employees.

The court additionally noted that the Defendant had reasonable preventative measures in place such that there was no basis to infer actual notice from the facts of this particular alleged existence of a spill.

The court stated that, without any evidence as to how the spill happened, how long it had been present, or any evidence that would show that it had been present for a long period of time, the Plaintiff was unable to establish constructive notice on the part of the defendant store.

As such, summary judgment was granted.

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

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

Source of image:  Photo by Fabio Bracht from

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