Last month, the Supreme Court of Iowa decided a premises liability case stemming from a 2010 accident. According to the court’s written opinion, a business guest at a hotel slipped and fell on the ice in the parking lot and broke her ankle. She brought a personal injury lawsuit, claiming that the hotel negligently caused her injuries because it did not maintain safe premises, did not properly train its employees, failed to warn its guests of the icy sidewalk, and caused ice to form. During the trial, the court instructed the jury on the negligent training theory but did not follow the proper doctrine. Furthermore, it also instructed the jurors on certain safety codes. The jury determined that the hotel was 98 percent liable and that the plaintiff was two percent at fault. She was subsequently awarded $1.2 million.
The defendants then appealed the decision, claiming that the jury instructions were erroneous. With regard to the negligent training theory, the defendants argued that the record did not contain evidence that imposed a duty of care on the hotel. The plaintiff contended that expert testimony was not required. However, the Supreme Court held that there must be some evidence or testimony to support the instruction. Moreover, the Supreme Court found that the lower court incorrectly over-emphasized certain evidence. As a result of these missteps, the Supreme Court reversed the decision and award and ordered a new trial.
Special Issues in Negligent Training and Hiring Cases in New Mexico
The above case highlighted the importance of appropriate jury instructions and preparation in personal injury lawsuits. Unfortunately for the plaintiff, the decision was completely reversed, and a new trial was ordered because of these inappropriate jury instructions. This resulted in a dismissal of the jury award.