Wal-Mart Stores, Inc. v. Wright
774 N.E.2d 891 (2002)
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Rule of Law:
A company's internal safety rules or policies do not establish the legal standard of ordinary care in a negligence action. The standard of care is an objective one based on what a reasonably prudent person would do, not the subjective standard a company sets for itself.
Facts:
- Ruth Ann Wright was shopping at the “Outdoor Lawn and Garden Corral” of a Wal-Mart store in Carmel.
- Wright slipped on a puddle of water in the corral and sustained injuries.
- Wal-Mart maintained a “Store Manual” that contained detailed procedures for employees to follow regarding spills and other floor hazards.
- The manual instructed employees to react quickly to spills, never leave them unattended, cordon off the area, and use safety cones.
- At trial, there was conflicting testimony from various Wal-Mart employees and former employees about whether the Store Manual's safety procedures applied to the outdoor corral area where Wright fell.
Procedural Posture:
- Ruth Ann Wright sued Wal-Mart Stores, Inc. in an Indiana trial court for negligence.
- At the conclusion of a jury trial, the court gave Final Instruction 17 over Wal-Mart's objection, which allowed the jury to consider Wal-Mart's store manual as evidence of the degree of care Wal-Mart recognized as ordinary.
- The jury returned a verdict for Wright, finding Wal-Mart liable and assessing Wright's total damages at $600,000, which was reduced to $420,000 based on a finding of 30% comparative fault by Wright.
- Wal-Mart, as appellant, appealed the judgment to the Indiana Court of Appeals, arguing that the jury instruction was an incorrect statement of law.
- The Court of Appeals affirmed the trial court's judgment, holding the instruction was proper.
- The Supreme Court of Indiana granted Wal-Mart's petition to transfer the case.
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Issue:
Does a jury instruction that allows a company's internal safety rules to be considered as evidence of the degree of care it recognizes as 'ordinary care' incorrectly state the law by substituting a subjective standard for the objective standard of reasonable care?
Opinions:
Majority - Boehm, J.
Yes. The jury instruction incorrectly states the law because it improperly invites jurors to apply a subjective standard of care based on the defendant's internal rules rather than the required objective standard of ordinary care. The standard of care in a negligence action is external and objective, based on what a reasonably careful and prudent person would do under the circumstances, not on the individual judgment or internal policies of the particular actor. A company's self-imposed rules may exceed the requirements of ordinary care for reasons unrelated to safety, such as customer service or aesthetics, and should not be used to define the legal standard. While such rules are admissible as evidence, they are merely evidentiary and cannot serve as the legal standard itself. The instruction was not harmless error because the manual was a central and hotly contested part of the plaintiff's case, making it likely the erroneous instruction influenced the jury's verdict.
Analysis:
This decision reinforces the fundamental principle that the standard of care in negligence is objective, not subjective. It protects defendants from being held to a higher legal standard than the law requires simply because they have adopted more stringent internal policies. By clarifying that company manuals are merely evidence and not the legal standard, the court encourages businesses to implement best practices without fear that doing so will automatically create greater legal liability. This ruling guides lower courts to issue cautious limiting instructions when such evidence is presented, ensuring juries do not conflate a company's internal goals with its external legal duties.
