Miami, Florida, partners Raúl J. Chacón Jr. and Russell M. Pfeifer and associate Monika Ledlova secured an appellate victory in the Third District Court of Appeal with a written opinion affirming summary judgment they obtained in Miami-Dade County Circuit Court in a case involving a national retail client. The plaintiff filed a negligence lawsuit after tripping over a wooden display pallet at our client’s retail store. The trial court granted summary judgment based on the open and obvious doctrine, after the Miami team argued there were no hazardous conditions present on the premises and that the plaintiff’s fall resulted from her own lack of attention. Surveillance video of the incident played a pivotal role in supporting the team’s argument, showing the plaintiff’s failure to follow the designated pathway, and subsequently tripping over a wooden pallet on her second visit to the store the same day. The trial court ruled in favor of our client, granting summary judgment, and following a request for rehearing by the plaintiff reaffirmed its decision. The plaintiff appealed to the Third District Court of Appeal, which affirmed the summary judgment citing case law referenced in our answer brief. This win serves as a crucial precedent, strengthening the defense position for property owners and retailers statewide and opens the plaintiff to the recovery of taxable costs.