Crissy Allen v. Pinnacle Entertainment Inc.

Summary

The court grants defendants Pinnacle Entertainment Inc. and PNK Lake Charles LLC’s motion for summary judgment in a Louisiana premises-liability action arising from a trip-and-fall at a casino. The court concludes that the alleged 3/16-inch floor-slope deviation did not present an unreasonable risk of harm under the Louisiana Merchant Liability Act and that plaintiff’s causation theory was speculative. All claims are dismissed with prejudice, with the ruling benefiting all defendants.

Holdings

1. A 3/16-inch deviation in slope on an otherwise unobstructed wooden floor did not present an unreasonable risk of harm and therefore was not an unreasonably dangerous condition under Louisiana Revised Statute § 9:2800.6.
2. Allen’s evidence that the slight floor deviation caused her fall was speculative and insufficient to establish the factual support necessary for trial.
3. Summary judgment was proper because Allen failed to produce sufficient evidence of an actionable unreasonable risk of harm and therefore could not establish an essential element of her Merchant Liability Act claim.

Questions Presented

1. Whether the 3/16-inch deviation in the casino’s wooden floor constituted an unreasonably dangerous condition under Louisiana’s Merchant Liability Act.
2. Whether the evidence created a genuine dispute of material fact regarding the cause of Allen’s fall and the existence of an unreasonable risk of harm.
3. Whether defendants were entitled to summary judgment on Allen’s Louisiana premises-liability claims.

Disposition

dismissed