Evidence of prior spills is not enough to defeat summary judgment to the defendant in a slip and fall claim due to a substance on the floor.

The plaintiff attempted to defeat a motion for summary judgment by arguing that she fell due to a foreign substance on the floor. The motion court judge found that there were no facts that any substance was negligently left on the floor. The plaintiff argued that drinks were served and permitted in the area where she was bowling and that she had seen spills before. The court opined that having seen drinks spill before did not establish facts of negligence as to failure to ensure a safety policy.

_{Case Law Alerts, 4^th Quarter, October 2015}

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