Coyle v. United States, 954 F.3d 146

On November 14, 2010, Linda Coyle tripped at the TSA security area in JFK Terminal 5 when her four-wheeled carry-on "locked up" on a mat; she fell face-first and later discovered a broken nose.
Coyle identified a mat as the cause; she submitted photographs taken years later of a similar mat placed at the end of the conveyor where passengers collect items. The photographed mat has a yellow border; Coyle says the mat she tripped on was solid black. No contemporaneous measurements exist.
TSA disputed use/existence of mats at the time and the government did not produce an incident report or video that Coyle was told existed; TSA also stated its mats are less than one inch thick, while Coyle alleges the mat was about one inch thick.
Coyle sued under the Federal Tort Claims Act (FTCA). The case was transferred to the Eastern District of New York; liability discovery closed in 2016; the United States moved for summary judgment and the district court granted judgment for the United States on August 8, 2018.
New York law applies. The government concedes it owed a duty and that the mat was the proximate cause of the fall; the sole contested issue is whether placing the mat breached the duty of care (i.e., whether the condition was negligent).
The Second Circuit affirmed, holding that under New York’s "trivial defect" doctrine the mat’s condition and placement were trivial and therefore non-negligent as a matter of law.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether TSA breached its duty by placing a mat in passenger flow	Coyle: one-inch black mat on black floor created a hazardous, non-trivial condition causing the trip	U.S.: mat (if used) was a trivial, minor defect or did not exist; non-negligent placement	Held: Condition was trivial under NY law; no breach as matter of law; summary judgment affirmed
Whether post-incident photographs and testimony suffice to establish the condition	Coyle: photos and her testimony establish mat’s placement/dimensions for triviality analysis	U.S.: photos are years later; incident report/video not produced; factual dispute	Held: Court accepted Coyle’s evidence as sufficient for the triviality determination; differences (e.g., yellow border) not outcome-determinative

Hutchinson v. Sheridan Hill House Corp., 26 N.Y.3d 66 (2015) (discusses New York’s trivial defect doctrine and instructs courts to decide triviality by reviewing all facts)
Guerrieri v. Summa, 598 N.Y.S.2d 4 (App. Div. 1993) (recognizes that trivial walkway defects that merely cause a stumble are not actionable)
Solomon v. City of New York, 66 N.Y.2d 1026 (1985) (sets forth the basic negligence elements: duty, breach, proximate cause)
Ya-Chen Chen v. City Univ. of N.Y., 805 F.3d 59 (2d Cir. 2015) (states de novo standard of review for summary judgment decisions)