Taylor v. Community Hospitals of Indiana, Inc., 949 N.E.2d 361

Taylor, visiting her husband at the Hospital, slipped near an elevator in the ground-floor lobby after weather of rain and sleet.
She alleged the Hospital negligently maintained walkways and public areas, causing her fall.
Price, a hospital security guard, found Taylor on her back and reported the floor as dry apart from her spilled food.
Taylor testified she did not see anything on the floor but assumed something caused her fall; she could not confirm a wet surface.
The Hospital moved for summary judgment, arguing negligence could not be proven without speculation, citing designated evidence (Taylor deposition, interrogatories, Price affidavit, incident report).
The trial court granted summary judgment; on appeal, the court affirming that Taylor could not prove causation or a negligent condition.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred in granting summary judgment.	Taylor argues there is a triable issue of fact on causation and duty.	Hospital asserts no genuine issue; plaintiff's claim rests on speculation.	No genuine issue; summary judgment affirmed.

Hale v. Community Hosp. of Indianapolis, Inc., 567 N.E.2d 842 (Ind.Ct.App.1991) (negligence not inferred from mere accident; must show causal link)
Daub v. Daub, 629 N.E.2d 873 (Ind.Ct.App.1994) (causation requires proof beyond speculation; but-for cause)
Harradon v. Schlamadinger, 913 N.E.2d 297 (Ind.Ct.App.2009) (summary judgment appropriate when undisputed evidence negates negligence element)
Scott County Family YMCA, Inc. v. Hobbs, 817 N.E.2d 603 (Ind.Ct.App.2004) (jury must not leap from reason to speculation; evidence must show more than mere accident)
Midwest Commerce Banking Co. v. Livings, 608 N.E.2d 1010 (Ind.Ct.App.1993) (causation cannot be inferred from alleged condition alone)
Landmark Health Care Assocs., L.P. v. Bradbury, 671 N.E.2d 113 (Ind.1996) (standard for granting summary judgment in negligence cases)