Valerie Miller v. Jackson-Madison County General Hospital District
W2016-01170-COA-R3-CV
| Tenn. Ct. App. | Dec 8, 2016Background
- On May 10, 2012, Valerie Miller slipped and fell on water in a hallway at Jackson‑Madison County General Hospital while visiting a patient and injured her back and knee.
- Miller sued the Hospital under the Tennessee Governmental Tort Liability Act (GTLA), alleging negligent maintenance and seeking $25,000.
- At bench trial the Hospital stipulated its employees primarily moved the nearby food cart, but presented no evidence on causation or notice; Miller’s testimony was the only evidence about the water.
- Miller testified she saw a trail of water leading to a food cart after she fell but did not know how long the water had been there, who caused it, or whether hospital employees knew about it.
- The trial court found insufficient evidence of actual or constructive notice and entered judgment for the Hospital. Miller appealed.
- The Court of Appeals affirmed, concluding Miller failed to prove the Hospital caused the condition or had actual/constructive notice, and res ipsa loquitur did not apply given other plausible explanations for the water.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Hospital was negligent because water came from a food cart under hospital control | Miller argued inference that employees (who controlled the cart) caused the leak supports liability | Hospital argued Miller offered no proof employees caused or knew of the water and other explanations exist | Held for Hospital: evidence insufficient to show causation or actual/constructive notice |
| Whether actual notice existed | Miller contended cart control supports inference staff knew of leak | Hospital: no evidence staff knew or were alerted to liquid | Held: no actual notice proved |
| Whether constructive notice exists (should have known) | Miller relied on inference from cart location and control | Hospital: no evidence of time liquid was present or prior similar incidents | Held: no constructive notice — duration not shown |
| Whether res ipsa loquitur applies | Miller argued circumstances permit inferring negligence without direct proof | Hospital argued other reasonable causes (visitors, accidental spill) negate exclusive control/inference | Held: res ipsa inapplicable; plausible non‑negligent explanations preclude the required inference |
Key Cases Cited
- Armbrister v. Armbrister, 414 S.W.3d 685 (Tenn. 2013) (standard of appellate review for bench trial findings)
- Nashville Ford Tractor, Inc. v. Great Am. Ins. Co., 194 S.W.3d 415 (Tenn. 2005) (preponderance standard to overturn trial court fact findings)
- Blair v. West Town Mall, 130 S.W.3d 761 (Tenn. 2004) (notice and causation principles in premises liability)
- Benson v. H.G. Hill, Inc., 699 S.W.2d 560 (Tenn. Ct. App. 1985) (wet‑floor inference where no other reasonable explanation existed)
- Underwood v. HCA Health Servs. of Tenn., Inc., 892 S.W.2d 423 (Tenn. 1994) (doctrine of res ipsa loquitur and its requirements)
- Burton v. Warren Farmers Coop., 129 S.W.3d 513 (Tenn. Ct. App. 2002) (limitations on res ipsa when inference would require a leap of faith)