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Case Law Update: Summary Judgment in Slip and Fall Cases

Reed v. Galaxy Holdings, No. 1-08-2443 affirmed a case where the plaintiff fell on puddle of water which had been tracked in from outside, on rainy day, when stepping from mat in entranceway of store onto bare floor of vestibule. Plaintiff made no allegation that water was anything other than natural accumulation, and Defendant store had no duty to remove water, regardless of store having not followed its usual protocol of warning signs and mopping on rainy days. Court refused to adopt federal courts’ “prescribed means” exception to natural accumulation rule, whereby business has duty to reasonably maintain sole point of entrance and exit for its business invitees. This Illinois case will greatly affect slip and fall cases.