Ellis v. Target Corporation

On October 3, 2018, Robert Ellis, a customer at a Target store in Atlanta, Georgia, slipped on a spilled liquid detergent in the cleaning supplies aisle. He sustained a herniated disc and a fractured ankle, requiring surgery and extensive physical therapy. Ellis filed a premises liability lawsuit against Target Corporation in federal district court, alleging the store failed to regularly inspect the floor or post warning signs about the hazardous condition. Surveillance footage revealed the spill had existed for over 30 minutes without any employee response, supporting the claim of constructive notice. Target argued that Ellis was comparatively negligent for failing to observe the obvious spill. The case proceeded to a jury trial focusing on the reasonableness of the store's safety protocols and the plaintiff's attentiveness.

The jury returned a verdict in favor of the plaintiff, apportioning 75% of fault to Target and 25% to Robert Ellis. The court entered a judgment awarding $320,000 in compensatory damages, which was reduced to $240,000 to reflect the plaintiff's share of negligence. Target did not appeal the decision.

Whether Target Corporation had constructive notice of the dangerous spill and failed to take reasonable remedial measures within a reasonable time, and to what extent the plaintiff's own inattention contributed to the accident under Georgia's comparative negligence rules.

The case reinforced the duty of large retailers to implement systematic floor inspection and prompt spill response procedures. Following the verdict, Target expanded its safety audit technology and employee training programs nationwide. The decision is frequently cited in slip-and-fall litigation to illustrate constructive notice based on the duration a hazard remains unaddressed.