Goodwin v. Al J. Schneider Co.
501 S.W.3d 894
| Ky. | 2016Background
- Plaintiff Ralph Goodwin slipped entering a bathtub in a Galt House hotel room in Aug. 2011, injuring his knee; the tub had a grab bar but no bathmat.
- After the fall hotel staff provided Goodwin a bathmat and other convention attendees reported their rooms had bathmats.
- Goodwin sued alleging invitee status, a dangerously slippery tub, the hotel’s knowledge or constructive knowledge, and failure to remove or warn.
- Galt House moved for summary judgment arguing Goodwin’s own negligence and that a wet tub is an open-and-obvious hazard; trial court granted summary judgment.
- The Court of Appeals affirmed, concluding a wet tub is an open-and-obvious danger and that the hotel had no duty to provide bathmats as a matter of law.
- The Supreme Court granted review to address application of Shelton and reversed and remanded, holding the focus on whether the hotel breached its duty to take reasonable steps to eliminate unreasonable risks.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a hotel’s failure to provide bathmats can breach its duty of care | Galt House’s failure to provide bathmats (while providing some) breached its duty to remove unreasonable risks | No common-law, statutory, or industry duty to provide bathmats; a wet tub is open-and-obvious so no liability | Court: Duty exists regardless of obviousness; issue is breach — failure to provide bathmats can be breach depending on reasonableness; remand for fact-based inquiry |
| Whether an open-and-obvious condition negates a landowner’s duty | Open-and-obvious does not eliminate the hotel’s duty to discover and eliminate unreasonable dangers | Open-and-obvious hazards absolve landowner from liability as a matter of law | Court: Open-and-obvious eliminates duty to warn but not the general duty of reasonable care; foreseeability and reasonableness govern breach |
| Proper standard for summary judgment in premises liability | Summary judgment improper if there is any genuine issue about reasonableness or foreseeability | Summary judgment appropriate when hazard is open-and-obvious and no duty to remedy exists | Court: Apply Steelvest standard; summary judgment only when impossibility of recovery or undisputed reasonableness of landowner’s conduct |
| Role of plaintiff’s awareness in negligence/comparative negligence | Plaintiff’s knowledge reduces recovery but does not bar claim under comparative negligence | Plaintiff’s prior use and awareness negate breach as a matter of law | Court: Plaintiff’s knowledge is relevant to comparative fault but does not automatically defeat claim; factual question for jury or further summary-judgment record |
Key Cases Cited
- Kentucky River Medical Center v. McIntosh, 319 S.W.3d 385 (Ky. 2010) (open-and-obvious label does not automatically bar liability; foreseeability and reasonableness control)
- Shelton v. Kentucky Easter Seals Soc’y, 413 S.W.3d 901 (Ky. 2013) (landowner owes invitee duty to discover and eliminate or warn of unreasonably dangerous conditions; obviousness eliminates duty to warn but not the duty of care)
- Carter v. Bullitt Host, LLC, 471 S.W.3d 288 (Ky. 2015) (reiterates Shelton; reasonableness and foreseeability determine breach; summary judgment appropriate only when situation cannot be corrected or landowner did all that was reasonable)
- Steelvest, Inc. v. Scansteel Serv. Ctr., Inc., 807 S.W.2d 476 (Ky. 1991) (standard for summary judgment: no genuine issue of material fact and impossibility for respondent to prevail)