Lane v. Hardee's Food Systems, Inc.
184 F.3d 705 (1999)
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Rule of Law:
A plaintiff in a negligence action presents sufficient evidence to survive a motion for judgment as a matter of law by providing circumstantial evidence from which a jury could reasonably infer that it was more likely than not that the defendant business, rather than a third party, created the dangerous condition.
Facts:
- On November 2, 1995, Donald Lane visited a Hardee's restaurant in Harrisburg, Illinois, shortly after 10:00 a.m.
- Hardee’s had an established policy of cleaning and mopping its restrooms every day after the breakfast service ended at 10:30 a.m.
- Lane ordered a drink and smoked a cigarette, which took about ten minutes.
- Based on his arrival time, Lane entered the restroom sometime between 10:26 a.m. and 10:45 a.m.
- Lane did not see any warning signs indicating a wet floor.
- While exiting the restroom, Lane slipped on what he described as standing water near a drain.
- As a result of the fall, Lane sustained injuries to his head and neck.
Procedural Posture:
- Donald Lane sued Hardee’s Food Systems, Inc. in an Illinois state court.
- Hardee’s removed the case to the U.S. District Court for the Southern District of Illinois.
- The defendant's motion for summary judgment was denied and the case proceeded to a jury trial.
- At the close of the plaintiff's case-in-chief, the district court granted judgment as a matter of law in favor of the defendant, Hardee's.
- Lane, as the appellant, appealed the district court's judgment to the U.S. Court of Appeals for the Seventh Circuit.
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Issue:
Does a plaintiff in a slip-and-fall case present sufficient evidence for a negligence claim to survive a judgment as a matter of law by showing that the accident occurred around the time the defendant business had a policy of cleaning the area, even without direct evidence that the cleaning occurred or caused the hazard?
Opinions:
Majority - Flaum, Circuit Judge
Yes. A plaintiff presents sufficient evidence for a negligence claim to reach a jury by establishing a basis for a reasonable inference of the defendant's culpability. Under Illinois law, a business is liable for a hazard created by its own agents. To prove this, a plaintiff must show the foreign substance was related to the defendant's business and produce evidence making it more likely than not that the defendant was responsible for it. Here, water in a restroom is related to Hardee's business of maintaining clean facilities. A jury could reasonably infer from Hardee's daily policy of mopping the restroom after 10:30 a.m. and the timing of Lane's fall that a Hardee's employee had recently mopped and negligently left the water. While this evidence is minimal and not the only possible conclusion, it is more than a 'mere scintilla' and is sufficient to support a verdict when viewed in the light most favorable to the plaintiff.
Analysis:
This decision clarifies the low evidentiary threshold required for a plaintiff in a slip-and-fall case to defeat a defendant's motion for judgment as a matter of law. It establishes that strong circumstantial evidence, such as a business's routine policies and the timing of an accident, can create a triable issue of fact for the jury regarding causation, even without direct evidence. The ruling reinforces the principle that trial courts should not weigh the strength of the evidence or assess credibility at this stage; so long as a reasonable inference of negligence is possible, the case must proceed. This precedent makes it more difficult for business defendants to win negligence cases before they reach a jury when the facts align with the business's known operational procedures.
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