Susan Aranda v. the Willie Limited Partnership D/B/A Antler Mini Storage
03-15-00670-CV
| Tex. App. | Dec 16, 2015Background
- Plaintiff Susan Aranda tripped and injured her shoulder while entering a leased storage unit at Antler Mini Storage on November 22, 2012; the unit had an unmarked step/ledge and poor lighting.
- Aranda testified she did not know of the ledge, tripped entering the unit while carrying boxes, and later discovered the elevated, unmarked step.
- Expert inspection and photographs allegedly show the riser/tread configuration violated building codes and the unit’s riser was substantially higher than surrounding units.
- Antler employees acknowledged poor lighting but did not warn specifically of the ledge or otherwise mark/modify the step.
- Antler filed traditional and no‑evidence summary judgment motions; the trial court granted both motions and sustained plaintiff’s evidentiary objections to certain defendant evidence (marijuana use).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the ledge constituted an unreasonably dangerous condition | The unmarked, unusually high riser combined with poor lighting and code violations made the entrance unreasonably dangerous | The risk was not shown as a matter of law (defense asserted insufficient proof) | Trial court granted summary judgment for defendant (appeal contests this) |
| Whether Antler had actual or constructive knowledge of the dangerous condition | The ledge existed since construction (1996) and staff acknowledged lighting problems—so Antler knew or should have known | No adequate proof Antler had notice or that reasonable inspections would have revealed the hazard | Trial court granted summary judgment for defendant (appeal contests this) |
| Whether Antler provided an adequate warning or remedied the condition | Warning only referenced lighting; no marking or repair of the ledge—warning was inadequate | Defendant contends any warning/effort was sufficient or plaintiff’s conduct caused injury | Trial court granted summary judgment for defendant (appeal contests this) |
| Causation—did the ledge cause Aranda’s injuries? | Aranda and witnesses testified she tripped on the ledge; engineer opined the riser caused the fall | Defendant argued plaintiff’s testimony was speculative and presented alternative explanations (and introduced contested evidence) | Trial court granted summary judgment for defendant (appeal contests sufficiency of evidence) |
Key Cases Cited
- Boerjan v. Rodriguez, 436 S.W.3d 307 (Tex. 2014) (no‑evidence summary judgment standards)
- Henkel v. Norman, 441 S.W.3d 249 (Tex. 2014) (adequacy of warnings in premises liability)
- TXI Operations, LP v. Perry, 278 S.W.3d 763 (Tex. 2009) (vague warnings may be insufficient to discharge duty)
- Del Lago Partners v. Smith, 307 S.W.3d 762 (Tex. 2010) (constructive knowledge and time‑notice rule for premises defects)
- Seideneck v. Cay Bayreuther Assocs., 451 S.W.2d 751 (Tex. 1970) (definition of unreasonably dangerous condition)
- Marathon Corp. v. Pitzner, 106 S.W.3d 724 (Tex. 2003) (limits on inference where basic facts of injury are unclear)