Leonard-Carter v. United States, 1:24-cv-07894

Plaintiff brought a slip-and-fall claim against the United States under the Federal Tort Claims Act after slipping in a United States Postal Service facility.
Plaintiff alleged her fall was caused by a wet floor left by a janitor’s mopping.
Defendant moved for summary judgment, arguing the floor was wet due to customers tracking in moisture from a concurrent snowstorm, not due to mopping.
Plaintiff cross-moved for spoliation sanctions based on defendant’s failure to preserve surveillance video of the incident.
The court reviewed photographs taken immediately after the fall showing the floor and considered weather records from a nearby airport to confirm the storm.
No official notice of the fall was given to the Postal Service before the video was overwritten, and there was no dispute plaintiff fell on a wet area.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Cause of wet floor	Floor was wet due to janitor’s mopping	Floor was wet due to tracked-in moisture from storm	No reasonable factfinder could conclude mopping caused the slip
Actual or constructive notice	USPS knew/should have known floor was wet	Wetness was obvious and due to a storm	No duty to warn of obvious storm-related wetness
Admissibility of weather evidence	JFK Airport weather data too remote	Other corroborating evidence establishes storm	Evidence sufficient; plaintiff lacks contrary proof
Spoliation/default sanction	Failure to preserve video merits sanction	No official notice given; no prejudice to plaintiff	No spoliation; plaintiff suffered no prejudice

Solazzo v. New York City Transit Auth., 6 N.Y.3d 734 (N.Y. 2005) (property owner has no duty to warn of obvious storm-related hazards)
Monroe v. United States, 415 F. Supp. 3d 315 (E.D.N.Y. 2019) (no duty to warn of obvious dangers due to tracked-in moisture)
Holland v. United States, 918 F. Supp. 87 (S.D.N.Y. 1996) (generally no liability for property owners for tracked-in rain or snow inside)