Saalfield Shad, P.A. is pleased to recognize Joseph B. Stokes, III and Angelica Inclan Lynch for obtaining a Final Summary Judgment on behalf of a national retail client in a St. Johns County premises liability lawsuit. The case arose from a September 2024 incident in which Plaintiff alleged she slipped and fell on the flooring of a store fitting room while trying on clothing.
Mr. Stokes and Mrs. Lynch moved for summary judgment on several grounds. First, the pair argued that under Section 768.0755, Florida Statutes, Plaintiff bore the burden of proving that our client had actual or constructive knowledge of the alleged dangerous condition, and the record evidence showed she could not meet that burden. They pointed to Plaintiff’s own deposition testimony, in which she confirmed she saw nothing on the floor before or after her fall, felt nothing when she ran her hand across it, and could not identify what, if anything, caused her to slip. Second, an eyewitness employee likewise found no substance or hazard on the floor when responding to the incident. Third, an independent civil engineer’s inspection and slip-resistance testing confirmed that the flooring exceeded both ADA and OSHA slip-resistance guidelines and was not the cause of the fall.
The Court agreed that Plaintiff could not establish notice or a hazardous condition sufficient to survive summary judgment and entered Final Judgment in favor of the Defendant on all counts. Stokes and Lynch’s win reinforces the protections Florida’s transitory foreign substance statute affords to business owners and highlights the value of thorough incident documentation and expert analysis in defending premises liability claims.
As an independent, Jacksonville-based civil litigation law firm, the attorneys at Saalfield Shad, P.A. have represented self-insured entities and insurance companies in North Florida for decades. The firm’s lawyers have extensive trial experience in state and federal courts, exceptional litigation skills, and diversified practices. With deep local ties in the community, they have built a reputation for successful representation, proactive and personalized counsel, and outstanding client service.
Disclaimer: Prior results achieved by Saalfield Shad, P.A. do not guarantee a similar outcome for other clients.