Bryan Bank & Trust v. Steele, 326 Ga. App. 13

Steele fell on the Bank sidewalk; investigation of cause contested.
Steele observed a two-to-three-inch black edging border around a flower bed; described as metal and protruding.
Steele could not state the cause of her fall with certainty; she speculated about the fence protruding onto the sidewalk.
Bank moved for summary judgment arguing no hazardous condition was proven; trial court denied the motion.
Appellate court reversed holding no evidence connected the fence border to Steele's fall; causation not established.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Existence of a hazardous condition and causation	Steele argues the border protruded, causing the fall.	Bank contends no evidence shows a hazard caused the fall.	Hazard not proven; no causal link established.
Evidence sufficiency for causation beyond speculation	Steele claims inference from border protrusion shows causation.	Bank shows no direct evidence linking border to fall.	No triable issue; speculation insufficient.

Lau’s Corp. v. Haskins, 261 Ga. 491 (405 SE2d 474) in 1991 (1991) (establishes burden-shifting in summary judgment and evidence standards)
Taylor v. Thunderbird, Lanes, 324 Ga. App. 167 (748 SE2d 308) in 2013 (2013) (premises-liability causation framework for hazardous conditions)
J.H. Harvey Co. v. Reddick, 240 Ga. App. 466 (522 SE2d 749) in 1999 (1999) (evidence of foreign substance as potential cause may be inferred)
Imperial Investments Doraville v. Childers, 303 Ga. App. 490 (693 SE2d 834) in 2010 (2010) (need for evidence beyond speculation to show cause of fall)
Avery v. Cleveland Ave. Motel, 239 Ga. App. 644 (521 SE2d 668) in 1999 (1999) (admitted speculation cannot establish causation)
Hood v. Todd, 287 Ga. 164 (695 SE2d 31) in 2010 (2010) (de novo review standard on appeal from summary judgment)