Court Rules that Placement of Wet Floor Signs Constitute Adequate Warning

In the case of Pitts v. Sonesta Intern. Hotel, Corp., No. 231002600 (C.P. Phila. Co. Nov. 24, 2025 Moore, J.), the trial court issued a Rule 1925 Opinion requesting the Superior Court to affirm the trial court’s entry of summary judgment in favor of a hotel in a case where a Plaintiff slipped and fell on a wet floor in the hotel’s foyer area.

According to the Opinion, the Plaintiff slipped and fell in an area where a maintenance worker for the hotel had recently mopped the floor but had also put out yellow caution signs. Videos surveillance footage confirmed that the maintenance worker had put the signs out.

According to the Opinion, during her testimony, the Plaintiff acknowledged the presence of the signs inside the foyer. However, the Plaintiff claimed that she did not see the signs before she slipped and fell.

At trial, the court granted the defense Motion for a Non Suit on the basis that there was no genuine issue of material fact to be resolved by the jury once the Plaintiff rested and given that the Plaintiff had failed to establish a right to relief.

The court emphasized that, in Pennsylvania, a business owner had a duty to maintain a reasonably safe property and must either fix dangerous conditions or warn invitees about them.

The court additionally noted that invitees are expected to be aware of their surroundings in order to appreciate possible dangers and also to appreciate warnings of any hazards.

Here in this case, the court found that, by clearly placing the yellow “Wet Floor” signs on the floor in the hotel foyer, the Defendant had adequately warned the Plaintiff about the possibility of the foyer floor being slippery.

The court emphasized that the Plaintiff acknowledged the presence of the wet floor signs inside the foyer before she walked into the area. On cross-examination at trial, the Plaintiff agreed that she had seen at least one (1) of the yellow signs before she entered the foyer and prior to falling down. The trial court noted that, even viewing the evidence in a light most favorable to the Plaintiff, it was the trial court’s opinion that the Plaintiff had failed to meet her burden of proving that the Defendant was liable for her fall.

Notably, the court noted in its Opinion that the placement of yellow warning signs in and around the foyer was conduct that established that the Defendant had adequately warned the Plaintiff of the dangers of the wet floor.

The court rejected the Plaintiff’s suggestion that the hotel should have also have had someone standing near the foyer to tell customers inside the hotel that the floor was wet. The court found that this was not a reasonable requirement and that the law does not require a business owner to undertake such unreasonable measures to warn of hazards on the property.

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


Source: The Legal Intelligencer Common Pleas Case Alert, www.Law.com (March 5, 2026).

Source of image:  Photo by Sandiyu Nuryono on www.pexels.com.

Presence of Wet Floor Signs Does Not Establish That Floor Was Wet

In the case of Rubes v. Kohl’s Department Stores, Inc., 3:17-CV-1842 (M.D. Pa. June 29, 2018 Munley, J.), the court granted summary judgment in a slip and fall case.   In his decision, Judge James M. Munley of the Federal Middle District Court of Pennsylvania confirmed the well-established law that the mere occurrence of an accident does not establish negligent conduct on the part of another.  

In his Opinion, Judge Munley provides a detailed description of the current status of Pennsylvania law on a plaintiff's burden of proof in slip and fall matters.

The court noted that, at a minimum, a slip-and-fall plaintiff must produce some evidence either that the possessor of land had a hand in creating the allegedly dangerous condition, or that he or she had actual or constructive notice of that condition.  

In this matter, the court found that the Plaintiff presented no evidence of the condition of the floor where she slipped.  The evidence revealed that the Plaintiff walked into the store from the inclement weather outside, took three or four steps into the store, and slipped and fell.

The court otherwise noted that the presence of wet floor signs in the area of the Plaintiff’s alleged fall do not establish that the floor was actually wet, since wet floor signs can be set out on a precautionary basis.  

Anyone wishing to review a copy of this decision may click this LINK.  The companion Order dismissing this case can be viewed HERE.

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