Justia Injury Law Opinion Summaries
Articles Posted in District of Columbia Court of Appeals
Gant v. The Lynne Experience, LTD
Appellant Yvonne Gant sued The Lynne Experience LTD (TLE) and Giant Foods, LLC (Giant) for negligence after allegedly being struck and injured by a golf cart operated by a TLE employee. Gant claimed that TLE and Giant failed to properly train and supervise their employees, leading to her injuries. TLE moved to dismiss the case, arguing that the District of Columbia’s Workers’ Compensation Act (WCA) provided Gant’s exclusive remedy, thus removing the court’s jurisdiction over the matter. The Superior Court agreed, dismissing Gant’s claims against TLE with prejudice, and later granted summary judgment in favor of Giant, finding no employer-employee relationship that could support Gant’s negligence claim.The Superior Court determined that the WCA provided Gant’s exclusive remedy and that the District of Columbia Department of Employee Services (DOES) had primary jurisdiction over her claims. The court dismissed Gant’s claims against TLE with prejudice, reasoning that any claim under the WCA would be time-barred. Subsequently, the court granted summary judgment for Giant, based on undisputed evidence that Giant was merely a sponsor of the event and had no role in managing or supervising the staff involved.On appeal, Gant argued that TLE failed to secure payment of compensation as required by the WCA and that she should be allowed to maintain her civil action. Alternatively, she requested a stay to present her claim to DOES. The District of Columbia Court of Appeals agreed that the WCA appeared to provide Gant’s exclusive remedy but held that the Superior Court should have dismissed her claim without prejudice. The court affirmed the summary judgment in favor of Giant, noting that Gant failed to present any arguments against it on appeal.The main holding by the District of Columbia Court of Appeals was that the Superior Court should have dismissed Gant’s claim against TLE without prejudice, allowing her the opportunity to pursue her claim with DOES. The court affirmed the summary judgment for Giant, as there was no evidence to support an employer-employee relationship necessary for Gant’s negligence claim. View "Gant v. The Lynne Experience, LTD" on Justia Law
Greene v. Children’s National Medical Center
Carolyn Greene visited her grandson at Children’s National Medical Center and slipped in a hallway, allegedly due to liquid left by a floor scrubbing machine operated by a hospital custodian. Greene claimed there were no warning signs and sustained severe injuries from the fall. She sued the hospital for negligence, asserting that the hospital's employee created the hazardous condition.The Superior Court of the District of Columbia granted summary judgment in favor of the hospital, concluding that Greene failed to raise a genuine issue of material fact regarding whether the hospital was on notice of the wet floor. The court found that Greene's claims were speculative and lacked sufficient evidence to prove that the liquid was left by the scrubbing machine.The District of Columbia Court of Appeals reviewed the case and reversed the lower court's decision. The appellate court held that Greene presented enough evidence for a reasonable jury to conclude that the hospital's employee created the dangerous condition. This included Greene's testimony about the liquid and the scrubbing machine, expert testimony supporting her claims, and inconsistencies in the custodian's account. The court emphasized that the evidence should be viewed in the light most favorable to Greene, the non-moving party, and that credibility determinations are for the jury to decide.The appellate court concluded that a jury could reasonably find that the hospital was on constructive notice of the hazard created by its employee, thus making summary judgment inappropriate. The case was remanded for trial. View "Greene v. Children's National Medical Center" on Justia Law
Posted in:
District of Columbia Court of Appeals, Personal Injury