Wal-Mart Stores, Inc. v. Wright case summary
774 N.E.2d 891 (Ind. 2002)
Tort Law
PROCEDURAL POSTURE: In a slip-and-fall negligence action by plaintiff customer against defendant discount retailer, the retailer appealed from a judgment of the Indiana Court of Appeals that affirmed a trial court judgment on jury verdict in favor of the customer. The retailer argued that the trial court prejudiced it by giving an erroneous jury instruction.
OVERVIEW:
-The customer was injured when she slipped and fell in an outdoor lawn-and-garden area of the discount retailer's premises.
-At trial of her negligence lawsuit against the retailer, the retailer's procedures manual was admitted into evidence. Although there was plenty of evidence that not all the procedures were followed, it was not clear that they applied to outdoor areas.
-The trial court's jury instruction on standard of care indicated that the retailer's failure to follow its own procedures could prove negligence, but the high court held that this instruction misstated the law.
ANALYSIS:
-The retailer's adoption of high standards did not mean that the manual set a standard of ordinary care at that same level.
-The jury might reasonably have found that ordinary care demanded somewhat less.
-As the erroneous instruction had a great likelihood of having affected the verdict, a new trial was required.
RULES:
In a negligence action, the standard of conduct that the community demands must be an external and objective one, rather than the individual judgment, good or bad, of the particular actor. This door swings both ways.
-A defendant's belief that it is acting reasonably is no defense if its conduct falls below reasonable care.
-A defendant's belief that it should perform at a higher standard than objective reasonable care is equally irrelevant.
-A party's own rules of conduct are relevant and can be received into evidence with an express caution that they are merely evidentiary and are not to serve as a legal standard.
OUTCOME: The court reversed the judgment and remanded the matter for a new trial.
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774 N.E.2d 891 (Ind. 2002)
Tort Law
PROCEDURAL POSTURE: In a slip-and-fall negligence action by plaintiff customer against defendant discount retailer, the retailer appealed from a judgment of the Indiana Court of Appeals that affirmed a trial court judgment on jury verdict in favor of the customer. The retailer argued that the trial court prejudiced it by giving an erroneous jury instruction.
OVERVIEW:
-The customer was injured when she slipped and fell in an outdoor lawn-and-garden area of the discount retailer's premises.
-At trial of her negligence lawsuit against the retailer, the retailer's procedures manual was admitted into evidence. Although there was plenty of evidence that not all the procedures were followed, it was not clear that they applied to outdoor areas.
-The trial court's jury instruction on standard of care indicated that the retailer's failure to follow its own procedures could prove negligence, but the high court held that this instruction misstated the law.
ANALYSIS:
-The retailer's adoption of high standards did not mean that the manual set a standard of ordinary care at that same level.
-The jury might reasonably have found that ordinary care demanded somewhat less.
-As the erroneous instruction had a great likelihood of having affected the verdict, a new trial was required.
RULES:
In a negligence action, the standard of conduct that the community demands must be an external and objective one, rather than the individual judgment, good or bad, of the particular actor. This door swings both ways.
-A defendant's belief that it is acting reasonably is no defense if its conduct falls below reasonable care.
-A defendant's belief that it should perform at a higher standard than objective reasonable care is equally irrelevant.
-A party's own rules of conduct are relevant and can be received into evidence with an express caution that they are merely evidentiary and are not to serve as a legal standard.
OUTCOME: The court reversed the judgment and remanded the matter for a new trial.
---
Interested in learning how to get the top grades in your law school classes? Want to learn how to study smarter than your competition? Interested in transferring to a high ranked school?
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