Gleason v. Target Corporation
2:23-cv-11337
E.D. Mich.Nov 21, 2024Background
- Victoria Gleason sued Target Corporation after slipping and falling inside a Target store, fracturing her kneecap.
- Gleason claimed she slipped on water possibly from snow on shopping carts but admitted she did not see any liquid before or after her fall.
- She did not report the incident to Target staff at the time, only later that night.
- Gleason brought claims for premises liability, gross negligence, and nuisance under Michigan law.
- Target moved for summary judgment, arguing lack of evidence for any dangerous condition and legal deficiencies in Gleason's claims.
- The case was removed to federal court based on diversity jurisdiction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Premises Liability | Target failed to protect against dangerous conditions (snow/water from carts caused her fall). | No evidence a dangerous condition existed or that Target knew of one. | No evidence of breach or dangerous condition; summary judgment for Target. |
| Gross Negligence | Target's conduct was grossly negligent | No independent claim for gross negligence; no evidence of gross negligence. | Claim fails as matter of law and for lack of evidence. |
| Nuisance | Conditions at Target amounted to a nuisance | No interference with land or public rights; legal deficiency. | Plaintiff forfeited claim by not responding; claim fails as a matter of law. |
Key Cases Cited
- Hoffner v. Lanctoe, 821 N.W.2d 88 (Mich. 2012) (sets out the duty owed by landowners to invitees under Michigan premises liability law)
- Est. of Goodwin by Goodwin v. Nw. Michigan Fair Ass’n, 923 N.W.2d 894 (Mich. Ct. App. 2018) (describes the elements of a premises liability claim in Michigan)
- Adkins v. Thomas Solvent Co., 487 N.W.2d 715 (Mich. 1992) (explains the distinction between public and private nuisance in Michigan law)
- Sholberg v. Truman, 852 N.W.2d 89 (Mich. 2014) (defines what constitutes a public nuisance under Michigan law)
