Small v. Super Fresh Food Mkts., Inc
In Small v. Super Fresh Food Mkts., Inc., 2010 WL 530071, (Del. Super.) the Court addressed when expert testimony is required to establish the applicable standard of care.
In Super Fresh, the plaintiff slipped in a puddle of water on the floor of the supermarket. The Court held that the plaintiff was not required to present expert testimony on the whether or not the puddle of water created a dangerous condition which breached the grocer's duty of care.
The Court ruled that puddles of water on the floor are within common experience and also found that a grocer does not undergo special training in this regard.
Therefore, according to Super Fresh, the plaintiff was not required to present expert testimony on whether a puddle of water on the floor created a dangerous condition.