Coyle v. United States, No. 18-2929 (2d Cir. 2020)
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The Second Circuit affirmed the district court's grant of summary judgment in favor of the United States in a trip-and-fall case. Plaintiff tripped at a TSA checkpoint at JFK Airport when her suitcase's wheels locked up as she attempted to roll it over a thick mat that TSA placed in the flow of foot traffic.
The court held that, under New York's trivial defect doctrine, any identified defect in the condition or placement of the mat was trivial and hence non-negligent as a matter of law. In this case, the presence of a floor mat placed on the floor, even a one-inch thick black mat on a black floor, is—under the triviality doctrine—simply not a sufficiently dangerous condition to constitute negligence.
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