Smith v. U.S.

Federal 7th Circuit Court
Civil Court
Res Ipsa Loquitur
Citation
Case Number: 
No. 16-4085
Decision Date: 
June 23, 2017
Federal District: 
C.D. Ill.
Holding: 
Reversed and remanded

Dist. Ct. erred in granting defendant-govt.’s motion for summary judgment in plaintiff-pre-trial detainee prisoner’s action under Federal Tort Claims Act, alleging that he sustained injuries when he fell off stool in room at federal courthouse. Plaintiff presented evidence to establish negligence claim under doctrine of res ipsa loquitur so as to defeat instant summary judgment motion, where plaintiff stated he was injured under circumstances that ordinarily would not have occurred in absence of negligence by agency or instrumentality within defendant’s management or control, and plaintiff testified that instant stool, which was within govt.’s control, malfunctioned by wobbling and tipping backwards when he initially sat on it, which in turned caused him to fall off stool and incur his injuries. Fact that other prisoners had used same stool, or that govt. presented different theory of plaintiff’s injuries did not require different result. Also, fact that plaintiff was left in room with his attorney did not defeat notion that govt. exercised control over stool, where record showed that govt. employee had placed said stool in room prior to plaintiff’s entry into room.