Last month, an appellate court in Rhode Island issued a written opinion in a premises liability lawsuit that was brought by a tenant of an apartment complex who slipped and fell on a patch of black ice in the complex parking lot. At the conclusion of the plaintiff’s case against the complex’s management company, before the case was presented to the jury, the trial judge granted the defendant’s motion for judgment as a matter of law. The appellate court was tasked with determining whether the trial judge was proper to decide the case as a matter of law rather than submit the case to a jury for a factual resolution of the plaintiff’s claim.
In the above case, the appellate court determined that the lower court was improper to decide the case as a matter of law. The court explained that there was evidence presented by the plaintiff indicating that the defendant may have been negligent. Specifically, the plaintiff testified that the defendant would plow any fallen snow in the parking lot to an area that was slightly above the level of the parking lot. Thus, when the snow melted, water would run onto the parking lot, where it could later re-freeze, creating a hazard. Indeed, the plaintiff also presented evidence, through his wife’s testimony, that he had complained about these ice patches on numerous occasions.
Judgment as a Matter of Law in Maryland Courts
In Maryland personal injury cases, it is the judge’s job to rule on all legal issues. For example, a judge will often determine which evidence the jury is able to consider and instruct the jury on the law that pertains to the case. The jury’s job is to then apply the law as explained by the judge to the facts of the case, resolving any factual disputes.