Hagler v. Coastal Farm Holdings, Inc.

Under the doctrine of res ipsa loquitur, when a plaintiff does not supply evidence showing the injury was more likely than not caused by negligence on the part of the defendant, summary judgment in favor of the defendant is appropriate.

The Supreme Court heard this case on review from the Court of Appeals, which affirmed the Trial Court’s order of summary judgment in favor of Coastal Farm Holdings, Inc. (CFH). Hagler filed a personal injury negligence suit against CFH because a 15lb metal post-pounder fell on her foot while she was walking down an aisle in the store. CFH moved for summary judgment because Hagler failed to show that CFH knew, or should have known, the post-pounder was shelved in a dangerous manner. Hagler argued her testimony, coupled with a picture taken soon after the incident, was sufficient to survive summary judgment. On appeal, Hagler argued the doctrine of res ipsa loquitur applied. CFH renewed its argument that a storeowner is not liable for injuries from a falling object unless there is evidence that the owner knew, or should have known, that the object had fallen. The trial court granted summary judgment for CFH and the Court of Appeals affirmed. The Supreme Court held that when a plaintiff does not supply evidence showing the injury was more likely than not caused by negligence on the part of the defendant, summary judgment in favor of the defendant is appropriate. Furthermore, the Court agreed with the holdings of the lower courts that CFH is not liable for injuries from a falling object unless evidence is presented indicating that the owner knew or should have known that the object had fallen. Affirmed.