Carter v. Piggly Wiggly - Phenix City Alabama LLC

On November 20, 2018, Janice Carter visited a Piggly Wiggly store in Phenix City, Alabama, where she slipped on water and sustained injuries. She filed a negligence lawsuit against the store, alleging premises liability. The trial court granted summary judgment in favor of Piggly Wiggly, finding no evidence that the store had actual or constructive notice of the hazardous condition. Carter appealed, and the Alabama Supreme Court reversed the decision, concluding that there was a genuine dispute of material fact regarding whether the liquid had been on the floor long enough for the store to discover it, especially given the store manager's inspection shortly before the accident. The case was remanded for trial.

The Alabama Supreme Court reversed the summary judgment entered in favor of Piggly Wiggly and remanded the case back to the trial court for further proceedings.

Whether Piggly Wiggly had actual or constructive notice of the water on the floor that caused Carter's fall, and whether the trial court improperly granted summary judgment despite disputes over the duration and discoverability of the hazardous condition.

This case reinforced the standard for proving constructive notice in Alabama premises liability claims, underscoring that an owner's routine inspection does not automatically defeat a plaintiff's claim if a jury could reasonably infer the hazard existed long enough to be discovered and remedied.