Hall v. Dollar Tree Stores, Inc.

On October 1, 2018, plaintiff Hall was shopping at a Dollar Tree store in the United States when they were injured after tripping over merchandise boxes left in an aisle. Hall filed a negligence suit against Dollar Tree Stores, Inc., alleging the company failed to maintain a safe environment and did not warn of the tripping hazard. The defense argued that it had no actual or constructive notice of the specific boxes in the aisle. The court examined the incident under the mode-of-operation rule, considering whether the self-service, high-volume retail setting created a reasonably foreseeable risk of obstructed walkways that relieved the plaintiff of proving traditional notice requirements.

The court denied Dollar Tree's motion for summary judgment, holding that a jury could reasonably find the store's self-service operation created a foreseeable hazard, and the case proceeded toward trial or a settlement.

Whether the mode-of-operation rule applied to relieve the plaintiff of proving the store's actual or constructive notice of the hazardous condition, and whether the store exercised reasonable care under the circumstances.

The ruling reinforced the application of the mode-of-operation rule to discount and dollar stores, placing a heightened duty on retailers with self-service models to implement rigorous inspection and hazard-removal protocols to prevent customer injuries.