Woman Files Premises Liability Lawsuit Against Menards After Door Falls on Her

Illinois federal court allows jury to consider whether Menards may be liable for a customer’s injuries

A federal judge in Illinois recently ruled that a customer who claims she was injured when a display door fell on her while shopping at Menards presented enough evidence for a jury to consider whether the company may be held responsible in a premises liability lawsuit.

The decision was issued by U.S. District Judge Nancy L. Maldonado of the Northern District of Illinois on July 1, 2024. The judge denied Menard Inc.’s motion for summary judgment, meaning disputed questions involving the company’s duty, whether that duty was breached, and whether the alleged conduct caused the plaintiff’s injuries would remain for a jury to consider.

Quick Answer:
A business may face a premises liability claim when a customer is injured because of a dangerous condition on the property. In this case, the court concluded that factual disputes remained about whether the display presented a reasonably recognizable danger and whether Menards should be held responsible, allowing those questions to proceed to a jury.

What Happened at the Menards Store?

According to the lawsuit, the plaintiff was shopping at a Menards location in Evergreen Park, Illinois, in March 2019. She was discussing the dimensions of one door with a family member when she was allegedly struck by a different door that fell from a store display.

The plaintiff subsequently filed a personal injury lawsuit seeking more than $50,000 in damages. She alleged that the accident caused personal, permanent, and financial injuries.

The Customer Was Shopping for Doors

The plaintiff was discussing the size of one door with a family member while shopping inside the Menards store.

A Different Display Door Fell

According to the plaintiff, another door in the display fell and struck her while she was in the store.

The Customer Filed a Lawsuit

The plaintiff sought more than $50,000 in compensation, alleging that the incident caused lasting physical and financial harm.

The Case Will Be Evaluated by a Jury

The federal judge denied Menards’ motion for summary judgment, leaving disputed issues of liability for a jury to decide.

Why Menards Asked the Court to Dismiss the Claims

Menard Inc. filed a motion for summary judgment asking the court to rule in its favor before trial. The company argued that it did not owe the plaintiff a duty to warn or protect her from what it described as an open and obvious condition.

Menards also argued that, even if a duty existed, the company had not breached that duty because it did not create the allegedly dangerous condition or have notice of it. The company further disputed whether its conduct was the proximate cause of the plaintiff’s injuries.

What Is Summary Judgment?
Summary judgment is a procedure through which a court can resolve a case or particular claims when the law and undisputed facts show that a trial is unnecessary. When important facts remain genuinely disputed, however, those questions may need to be resolved by a jury.

What Is an “Open and Obvious” Condition?

One of the important issues in the case involved whether the condition that allegedly caused the plaintiff’s injury was sufficiently obvious that a reasonable person should have recognized the danger.

Menards relied on a decision from the U.S. Court of Appeals for the Seventh Circuit, Dunn v. Menard. In that case, a 16-foot stack of insulation fell on the plaintiff while he was loading a roll of insulation into his vehicle in a Menards self-service yard. The Seventh Circuit agreed that the stack presented an open and obvious condition in the circumstances of that case.

Judge Maldonado concluded that Dunn was factually distinguishable from the circumstances alleged in the present case. That distinction was important because premises liability questions often depend heavily on the specific facts surrounding the dangerous condition.

Menards’ Argument

The company argued that the condition was open and obvious and therefore did not create a duty to warn or protect the plaintiff from the alleged danger.

Plaintiff’s Evidence

Testimony from the plaintiff and her granddaughter indicated that some door stacks appeared straighter than others and that the door that fell appeared to be set up differently.

Why the Judge Sent the Issues to a Jury

The court considered testimony from the plaintiff and her granddaughter that some of the displayed doors appeared straighter than others and that the particular stack involved in the incident looked “weird.” According to the testimony described by the court, they did not want to touch the doors because they were concerned that they might fall.

Based on that evidence, the court was not persuaded that a reasonable customer would necessarily have recognized the risk before the accident. As a result, the court concluded that disputed questions regarding Menards’ potential responsibility should be determined by a jury rather than resolved through summary judgment.

What the Court Decided

Menards’ motion for summary judgment was denied, leaving disputed premises liability and negligence issues for a jury to consider.

What This Means for Premises Liability Claims

The case demonstrates why the circumstances surrounding a dangerous condition can be critical in a premises liability lawsuit. A business may argue that an accident was caused by a condition that any reasonable person would have noticed, while an injured customer may present evidence showing that the danger was not readily apparent.

Important evidence may include photographs of the area, surveillance footage, witness statements, store policies, employee testimony, incident reports, inspection records, and documentation showing whether the business knew or should have known about the hazardous condition.

Whether a property owner or business is legally responsible depends on the specific facts and applicable law. An attorney can evaluate the circumstances of an accident and determine what evidence may be necessary to support a premises liability claim.

Talk to a Springfield, IL Personal Injury Lawyer Today

Patel Law, PC represents the interests of Illinois residents who have been injured due to the negligence of another party. If you have suffered an injury on someone else’s premises, call our Springfield personal injury lawyers today to schedule a consultation so we can begin investigating your case right away.