Angela Delores Saunders visited a Home Depot store in Northville Township, Michigan in April 2020. While waiting in a checkout line that had been extended to allow for social distancing during the COVID-19 pandemic, Saunders stood behind another customer. A store employee was assigned to direct customer traffic.
A separate customer approached the front of the line and was instructed by the employee to move to the back. As that customer repositioned, the man standing in front of Saunders stepped backward to allow her into the line. He stepped on Saunders’s foot and collided with her, causing her to fall and suffer injury.
Saunders filed suit against Home Depot in Michigan state court in 2020. The case was removed to federal court, where the district court dismissed the complaint without prejudice. Saunders did not amend her complaint or appeal. She later filed a new lawsuit in 2023, which was again removed to federal court.
Home Depot moved to dismiss the 2023 complaint. The district court granted the motion, concluding that Saunders failed to state a claim. Saunders appealed the dismissal to the United States Court of Appeals for the Sixth Circuit.
The appellate court reviewed the dismissal under the Rule 12(b)(6) standard, which required the complaint to contain sufficient factual allegations to state a plausible claim for relief.
The court evaluated whether Saunders’s claim sounded in ordinary negligence or premises liability under Michigan law. Both types of claims required proof of duty, breach, causation, and damages. The court focused on whether Home Depot owed a duty under the circumstances.
The court determined that Saunders’s allegations were based on ordinary negligence rather than premises liability. Her claims centered on the conduct of a Home Depot employee directing customer traffic, not on a dangerous condition of the property itself.
The court reviewed the voluntary-assumption-of-duty doctrine, which applies when a party undertakes to perform an action and must do so with reasonable care. It also examined Michigan law addressing the limited duties owed by businesses when implementing safety measures.
Saunders alleged that Home Depot undertook measures to manage customer traffic and reduce the spread of COVID-19. The court found that these measures imposed a duty to exercise reasonable care in their implementation. The complaint itself described that Home Depot assigned an employee to direct customers and manage the line.
The court concluded that this duty did not extend to eliminating all risks of contact between customers. Michigan law does not impose liability on a business for failing to prevent every instance of negligent or inadvertent conduct by third parties, even when safety measures are in place.
The court found that Saunders’s allegations did not plausibly show that Home Depot breached any duty owed to her. The conduct described reflected efforts to manage customer flow rather than negligent implementation of safety measures.
The Sixth Circuit affirmed the district court’s dismissal. It held that Saunders failed to plausibly allege a negligence claim against Home Depot based on the facts presented.
If you have been injured due to unsafe property conditions, our team handles premises liability claims involving property owners, businesses, and other responsible parties. Contact us to learn how our team can assist with your claim.