Chambers v. Village of Moreauville, 85 So. 3d 593

Chambers tripped on a sidewalk deviation of 1.25–1.5 inches in Moreauville; the accident occurred while walking to Chambers’ home with Bowman.
Chambers sued the Village of Moreauville for damages in a bench trial; the trial court found Moreauville 100% at fault and awarded about $49,214.
Plaintiffs expert Beard claimed the ledge was a tripping hazard due to vertical change in elevation exceeding 0.5 inch.
Defendant’s expert Landreneaux argued the sidewalk condition was not unreasonably dangerous and that Chambers could have avoided the hazard.
The court of appeal partly affirmed and partly reversed, and this Court granted a writ to address whether the deviation created an unreasonable risk of harm, focusing on the cost factor in risk-utility balancing.
The Court concludes the deviation does not present an unreasonable risk of harm and reverses the lower courts, rendering judgment for the defendant.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the sidewalk deviation created an unreasonable risk of harm	Chambers argues the ledge is a tripping hazard and unreasonably dangerous	Moreauville contends the deviation is small, natural in origin, and not unreasonably dangerous	No; deviation not unreasonable; cost factor weighs against liability

Boyle v. Board of Supervisors, Louisiana State University, 685 So.2d 1083 (La. 1997) (risk-utility factors; small deviation not unreasonable)
White v. City of Alexandria, 216 La. 308, 43 So.2d 618 (La. 1949) (observability and voluntary conduct considerations in sidewalk defects)
Dupree v. City of New Orleans, 765 So.2d 1002 (La. 2000) (premises liability negligence and unreasonable risk framework)
Pryor v. Iberia Parish School Bd., 60 So.3d 594 (La. 2011) (risk-utility balancing test applied to sidewalk defects)
Shavers v. City of Baton Rouge/Parish of East Baton Rouge, 807 So.2d 883 (La. App. 1 Cir. 2001) (one-and-one-half inch deviation not per se unreasonable)