Knoxville Court Finds Property Owners Owed No Duty to Injured Woman in Premises Liability Case

The Court of Appeals of Tennessee at Knoxville has affirmed a summary judgment verdict issued in favor of two property owners in a premises liability lawsuit. In Smith v. Stanley, a woman sued the owners of a cabin after she purportedly suffered injuries when she fell down a set of stairs. According to the complaint, the Knoxville woman visited the cabin for the first time at night with the property owners’ adult children. As the plaintiff entered the cabin, she reportedly neglected to turn on a light switch located near the front door. Instead of asking her companions where the light switch was, she apparently walked into a room in the dark and tripped down a flight of stairs. As a result of her fall, the woman allegedly lost consciousness and suffered numerous injuries.

After the incident, the woman filed a premises liability lawsuit against the owners of the cabin. In order to recover for a premises liability claim in Tennessee, a plaintiff must prove that the property owner had a duty to protect the plaintiff, the owner breached that duty, and the breach resulted in an injury to the plaintiff. Additionally, a premises liability plaintiff must demonstrate that the dangerous condition which resulted in his or her injury was caused or created by the owner, or the owner had actual or constructive notice that the unsafe condition existed.

In response to the woman’s complaint, the defendants filed a motion for summary judgment. When a party to a lawsuit files a motion for summary judgment, the party is asking the court to rule that no genuine issue of material fact that would warrant a trial exists and any undisputed facts require judgment to be entered in his or her favor. According to the defendants, they did not owe the woman a duty because her actions were not reasonably foreseeable.

The trial court agreed with the cabin owners and entered summary judgment in their favor based upon Tennessee Supreme Court precedent in Eaton v. McClain. In that case, the court ruled that a property owner owed no duty to an overnight visitor who fell down a flight of stairs leading to a basement after she awoke and attempted to find a restroom in the dark without first turning on a hall light. Additionally, the Supreme Court stated the homeowners had no duty to warn their guest about the basement stairs since such a feature is commonplace in many homes.

The plaintiff in the instant case appealed the trial court’s decision to the Knoxville Court of Appeals. The appellate court agreed with the lower court and held the cabin owners did not owe the woman a duty. According to the court, stairs that lead to a basement are quite common and are not inherently dangerous. Because the plaintiff offered no proof of a hidden danger, the cabin owners had no duty to warn her that the stairs existed. Additionally, the court said it was not reasonably foreseeable that the woman would walk into a dark room she was unfamiliar with without attempting to turn on the lights. Since the property owners did not owe a duty to the injured woman, the appeals court affirmed the trial court’s decision and ruled in favor of the defendants.

A Tennessee property owner has a duty to exercise reasonable care in order to avoid causing injuries to persons who are legally on their property. If you were hurt because a property owner breached this duty, you have a right to have your case heard by a judge or jury. Because a property owner may try to dismiss your claim, you should have a knowledgeable local premises liability lawyer on your side to help you protect your rights and assist you in getting the compensation you deserve.

If you suffered a premises liability injury, please call Hartsoe Law Firm, P.C. at (865) 804-1011 or contact us through our website today. A Hartsoe Law Firm, P.C., there is always someone available to talk to you about your case.

Additional Resources: Smith v. Stanley, Tenn: Court of Appeals 2014

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