Here’s a breakdown of the 2024 Premises Liability case Albertsons, LLC d/b/a Randall’s v. Maryam Mohammadi from the Texas Supreme Court. You can read the full text of the opinion by clicking here.
Maryam Mohammadi slipped and fell at a Randall’s grocery store, allegedly because a puddle formed next to a shopping cart with leaking items. She sued Randall’s claiming they failed to warn about the wet floor.
The jury found no liability under the “constructive knowledge” standard — meaning they decided Randall’s did not reasonably should have known about the danger. Because the jury answered that way, they were not asked to consider liability under the “actual knowledge” standard — whether Randall’s actually knew about the wet floor.
The Court of Appeals reversed that decision, saying the jury should have been allowed to consider liability under actual knowledge even if the constructive knowledge claim failed. They relied on a precedent case (Corbin v. Safeway) which allowed actual knowledge to be inferred from an antecedent condition (like a leaking bag in the cart).
The Texas Supreme Court reversed the Court of Appeals. They said even if there was an error in not letting the jury consider actual knowledge, it was harmless because there was no evidence Randall’s actually knew about the wet floor. The wet floor itself, not the leaking bag (the antecedent condition), is what matters for actual knowledge in premises liability.
The Court emphasized that knowing about a condition that might lead to a hazard (like a leaking bag) is not the same as knowing about the hazard itself (the wet floor). Since no evidence showed Randall’s employees saw or knew of the wet floor before Mohammadi fell, no reasonable jury could have found actual knowledge.
So, the Supreme Court reinstated the trial court’s verdict in favor of Randall’s, ending Mohammadi’s claim.
In other words, the key legal takeaway is that in premises liability cases, actual knowledge must be about the dangerous condition itself at the time of injury — not just about something that might cause it. And if the jury properly found no constructive knowledge, lack of actual knowledge evidence means the verdict for the store stands.
Girards Law Firm specializes in severe injury and death cases in Texas, Arkansas & Oklahoma. Contact us at www.girardslaw.com and use the Chat feature for more information.