Under Tennessee law, summary judgment is a ruling that is reserved only for those cases where there are no disputes of material fact, and no way for the plaintiff or defendant to succeed in light of the facts that have been presented. Because the standard is so high, summary judgment is only rarely granted, and most cases are left for the jury to decide. Sometimes, however, courts may incorrectly read the facts, and believe that there is less dispute than there really is. When this happens, summary judgment can be granted inappropriately, as in a recent premises liability case.
In this case, A.S. sued S.S. for injuries that she incurred while catering an event at S.S.’s home. As part of the event, the caterers were required to use a back entrance and set of steps when coming in and out of the home. A.S. went up and down these steps several times over the course of the evening, in the light, without issue. However, at the end of the night, she descended the steps in the dark holding onto a railing. A.S. could not see the railing and did not notice that it had ended. As she leaned forward to continue to grab onto it, she fell forward and down the stairs, severely injuring herself. A.S. filed claims against S.S. alleging that S.S. had been negligent in failing to properly light the stairs and fix the guardrail. In response, S.S. initially argued that the stairs had been lit and that the area was not dangerous when A.S. descended.
Later on, after discovery was completed, S.S. moved for summary judgment and argued that, in fact, the lights had been off and the time of the accident and that A.S. was negligent for failing to turn them on before she descended the steps. The trial court agreed and granted the summary judgment motion. A.S. appealed.