This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
A customer at a retail store sat on a chair provided for customer use, which collapsed, causing her to fall and injure her arm. The store manager disposed of the chair pieces before the lawsuit was filed. The customer alleged negligence on the part of the store, claiming the chair was under the store's exclusive control and management.
Procedural History
- Trial Court: The trial court instructed the jury on the doctrine of res ipsa loquitur. The jury returned a verdict in favor of the defendant.
- Court of Appeals: The Court of Appeals affirmed the trial court's decision in an unpublished opinion.
Parties' Submissions
- Plaintiff: Argued that the store had exclusive control and management of the chair, and that the doctrine of res ipsa loquitur applied. The plaintiff objected to the trial court's additional instruction defining "exclusive control," arguing it imposed an improper evidentiary burden.
- Defendant: Contended that the chair was not under its exclusive control because other customers had access to it. The defendant argued that the jury instruction on "exclusive control" was appropriate and consistent with precedent.
Legal Issues
- Was the jury instruction on the definition of "exclusive control" under the doctrine of res ipsa loquitur appropriate?
- Did the plaintiff meet the burden of proof required to invoke the doctrine of res ipsa loquitur?
Disposition
- The Supreme Court of New Mexico reversed the decisions of the Court of Appeals and the trial court and remanded the case for a new trial.
Reasons
Per Ransom J. (Baca and Frost JJ. concurring):
The Court found that the trial court erred in its jury instruction defining "exclusive control" under the doctrine of res ipsa loquitur. The instruction improperly required the plaintiff to prove that no other party had equal access to the chair, which imposed an undue evidentiary burden inconsistent with the doctrine's principles.
The Court clarified that the doctrine of res ipsa loquitur applies when an injury occurs under circumstances that ordinarily do not happen without negligence, and the defendant has exclusive control over the instrumentality causing the injury. Ownership, maintenance, and provision of the chair by the store were sufficient to establish a prima facie case of exclusive control, even if other customers had access to the chair.
The Court distinguished this case from precedent involving merchandise displays, where customer access defeated exclusive control. It emphasized that the anticipated safe use of a chair by multiple customers does not negate the store's responsibility for its maintenance and safety.
The Court concluded that the plaintiff met her burden of proof under res ipsa loquitur, and the erroneous jury instruction constituted reversible error. A new trial was ordered to allow the jury to consider the case without the improper instruction.