Stribling v. Rushing's, Inc., 115 So. 3d 103

Stribling and Veal visited Piggly Wiggly in Jackson, MS (Nov. 26, 2008) where Bolden allegedly offered a watch and then shot Stribling in the parking lot.
Stribling filed suit (Jan. 29, 2010) against Rushing’s, Inc. and Stirling Properties for premises liability and related claims.
Circuit court granted summary judgment for defendants, finding no foreseeability or proximate cause and that Stribling was an invitee with no notice of danger.
Court held Stribling failed to show facts placing Piggly Wiggly or Stirling on notice of Bolden’s violent propensity or of a dangerous atmosphere on the premises.
This appeal challenges the summary judgment ruling on premises liability and negligent training theories.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Premises liability—negligence duties to invitees	Stribling argues Bolden’s violent propensity or atmosphere of violence breached duty.	Rushing’s/Stirling contend no notice or breach existed; no proximate cause.	No genuine issue; summary judgment affirmed.
Negligent training and hiring as proximate cause	Stribling claims failure to train Bolden proximately caused injuries.	Holistically, no evidence of foreseeability or negligent training; Foradori distinguished.	No genuine issue; summary judgment affirmed.

Jacox v. Circus Circus Miss., Inc., 908 So.2d 181 (Miss.Ct.App.2005) (premises liability duty to invitees to keep premises reasonably safe)
Newell v. S. Jitney Jungle Co., 830 So.2d 621 (Miss.2002) (duty to protect invitees from reasonably foreseeable injuries)
Foradori v. Harris, 523 F.3d 477 (5th Cir.2008) (facts show whether manager’s awareness created foreseeability and duty to control employees)
Holmes v. Campbell Properties, Inc., 47 So.3d 721 (Miss.Ct.App.2010) (negligent hiring/training requires foreseeability; distinguishable facts support summary judgment)
Hoffman v. Planters Gin Co., 358 So.2d 1008 (Miss.1978) (invitee status and premises duties—invitees are owed reasonably safe premises)