Michael Oien v. Home Depot U.S.A., Inc., No. 22-2374 (8th Cir. 2023)
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Plaintiff loaded purchases he made at a Home Depot store in Maplewood, Minnesota, on two flat carts. A Home Depot employee assisted Plaintiff by pushing one of the carts out of the store while Plaintiff followed, pushing the other. The exit doors automatically opened for the Home Depot employee and then closed while Plaintiff was exiting the store, tearing Plaintiff’s right rotator cuff and causing other injuries. Plaintiff alleged his injuries were caused by the door prematurely closing. The doors at issue were manufactured, installed, and serviced by Stanley. Plaintiff alleged a negligence claim against Home Depot and claims of strict product liability, negligence, and breach of express and implied warranties against Stanley. The district court granted summary judgment in favor of Defendants on all claims.
The Eighth Circuit affirmed. The court explained that Plaintiff offered no evidence that Home Depot caused the alleged dangerous condition or that it had actual knowledge of the existence of the alleged dangerous condition. Instead, he argued that Home Depot should have known of the existence of the problem with the automatic doors. But Plaintiff did not retain an expert, nor did he offer evidence demonstrating that Home Depot should have known the automatic doors might close while a customer was entering or exiting the store. The court wrote that because Plaintiff did not submit any evidence indicating the automatic sliding doors were unsafe or an inspection of the doors would have revealed the alleged dangerous condition, Home Depot is entitled to summary judgment on Plaintiff’s negligence claim.
Court Description: [Erickson, Author, with Shepherd and Grasz, Circuit Judges] Civil case - Product liability. Plaintiff sued the store and the manufacturer of the automatic sliding door at the store's entrance after he was injured as he was walking out of the store; the district court granted the defendants summary judgment. Held: (1) the district court did not err in finding plaintiff had failed to create an issue of material fact demonstrating the store either caused a dangerous condition on the premises or knew, or should have known, that the condition existed; (2) the district court correctly determined the facts did not warrant the application of the doctrine of res ipsa loquitur; and (3) plaintiff failed to show a door malfunction caused his injuries.
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