Lyle Dumont and Helen Dumont v. Quincy Place Holdings LLC, Lexington Realty International, LLC, and Michael Nelson, d/b/a QPM Property Maintenance & Janitorial, 20-1054

On March 4, 2017, Lyle Dumont fell entering Quincy Place Mall while attending a train show; he filed a premises-liability suit against the mall owner (Quincy Place Holdings, LLC) and the janitorial contractor (Michael Nelson/QPM).
Lyle did not see the rug folded over before his fall; a mall-walker witness offered a hypothesis about sand, carts, and traffic causing a rug to curl but did not see the fall or key events and gave no direct observations of sand or a curled rug before the incident.
Defendants submitted uncontroverted affidavits that staff cleaned under the rugs nightly and inspected the area about twenty minutes before the fall without observing the rug folded-over.
The district court granted summary judgment for defendants; the Dumonts appealed, arguing the evidence—viewed in their favor—created genuine issues on negligence.
The court analyzed duty/breach under the Restatement (Third) approach adopted in Iowa caselaw and focused on whether plaintiffs produced evidence of actual or constructive notice and causation.
The court held the Dumonts failed to produce non-speculative evidence on breach (notice) and causation, so they could not make a prima facie negligence case; summary judgment was affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether plaintiffs produced evidence of breach/notice to survive summary judgment	Dumonts: accumulation of sand under heavy rugs, carts, increased foot traffic, and lighting created an ongoing dangerous condition that should have put defendants on notice	Defendants: nightly cleaning and a staff inspection 20 minutes before the fall show no notice; plaintiff/witness testimony is speculative and lacks direct observation	No — insufficient evidence of actual or constructive notice; breach not shown
Whether plaintiffs established causation between the rug condition and the fall	Dumonts: the rug curled and caused Lyle’s fall	Defendants: no evidence the rug was curled prior to the fall or that the alleged conditions caused the curl; witness did not see the fall; causation is speculative	No — causation not supported by non-speculative evidence; summary judgment proper

Susie v. Family Health Care of Siouxland, P.L.C., 942 N.W.2d 333 (Iowa 2020) (summary judgment review and burden on moving party)
Homan v. Branstad, 887 N.W.2d 153 (Iowa 2016) (material fact and drawing inferences for nonmoving party)
Benham v. King, 700 N.W.2d 314 (Iowa 2005) (actual or constructive knowledge required to impose liability)
Ludman v. Davenport Assumption High Sch., 895 N.W.2d 902 (Iowa 2017) (adoption of Restatement (Third) standard for landowner duty)
Walls v. Jacob N. Printing Co., 618 N.W.2d 282 (Iowa 2000) (elements of negligence)
Banwart v. 50th St. Sports, LLC, 910 N.W.2d 540 (Iowa 2018) (nonmoving party must set forth specific facts to create a genuine issue)
Phillips v. Covenant, 625 N.W.2d 714 (Iowa 2001) (inferences based on speculation are not legitimate)