Williams v. State Farm Insurance Co., 103 So. 3d 433

Williams, a store patron, claims she tripped on gravel on concrete steps at Feed Sales & Service in Shreveport, injuring her left foot.
The steps were poured-in-place concrete with steel-brush finish and red-painted edges, plus two side handrails.
The incident occurred July 3, 2006; Williams sued Sellers, the store owner, and State Farm Insurance.
A bench trial resulted in judgment for defendants; the court noted Williams was an incredible witness and credited Sellers.
Louisiana RS 9:2800.6 governs merchant premises-liability claims; plaintiff must prove three elements: unreasonable risk, notice, and failure to exercise reasonable care.
The appellate court affirmed, holding Williams failed to prove the steps posed an unreasonable risk of harm and thus failed to establish a merchant-liability claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the steps posed an unreasonable risk of harm under RS 9:2800.6	Williams argues gravel on steps created an unreasonable risk and was foreseeable	Sellers contends no unreasonable risk; testimony contradicts Williams	No reversible error; Williams failed to prove an unreasonable risk under RS 9:2800.6

Davis v. Wal-Mart Stores, Inc., 774 So.2d 84 (La. 11/28/00) (defines elements of merchant liability under RS 9:2800.6)
Chunn v. Brookshire Grocery Co., 18 So.3d 179 (La.App.2d Cir. 2009) (reiterates burden under RS 9:2800.6 and standard of review)
Harrison v. Horseshoe Entertainment, 823 So.2d 1124 (La.App.2d Cir. 2002) (premises liability elements and credibility deference)
Stobart v. State through Dept. of Transp. and Development, 617 So.2d 880 (La.1993) (manifest error standard in credibility/choice of fact)
Easter v. Direct Ins. Co., 957 So.2d 323 (La.App.2d Cir. 2007) (credibility and sufficiency in appellate review of factual findings)
Daigle v. City of Shreveport, 78 So.3d 753 (La.App.2d Cir. 2012) (illustrates appellate review in Louisiana premises liability)