In Jackson v. K-Mart Corp., 251 Kan. 700, 840 P.2d 463 (1992), Jackson was walking down an aisle in a K-Mart department store when she slipped and fell near a clothing rack. In the middle of the tile floor near the rack was a green liquid that was apparently avocado juice. Jackson did not see the juice or know how it got there or how long it had been there. Jackson later heard a K-Mart employee say a woman had passed through the area where Jackson fell and was accompanied by a small child carrying a can of avocado juice. The store operated an in-store cafeteria and allowed customers to remove food and drink from the cafeteria and carry it onto the shopping floor. Jackson testified the cafeteria sold cans of avocado juice, although K-Mart alleged that an employee found a can of avocado juice near the location of Jackson's fall bearing a Wal-Mart label. The district court granted summary judgment for K-Mart because Jackson did not establish that K-Mart had either actual notice of the spill or constructive notice based on the length of time the spill existed. The district court further ruled that the general rule in Kansas is that where an individual is injured as a result of a fall caused by a dangerous condition not created by the proprietor but from other persons' actions, proof is required that the proprietor knew or should have known of the condition. The Court reversed the district court and adopted the mode-of-operation rule, "which allows a customer injured due to a condition inherent in the way the store is operated to recover without establishing that the proprietor had actual or constructive knowledge of the dangerous condition." 251 Kan. at 702. The case was remanded for a determination of whether the dangerous condition due to K-Mart allowing customers to carry food and drink into the shopping area was reasonably foreseeable and, if so, whether reasonable care had been exercised. On subsequent review by the Supreme Court, the court noted that the mode-of-operation rule is part of the trend of liberalizing the rules restricting recovery by one injured on the premises of another. 251 Kan. at 706. The court also discussed the rise of self-service marketing where customers are free to browse, examine, and select merchandise for themselves and recognized this method of shopping increases the risk of dangerous conditions being created. 251 Kan. at 707. The mode-of-operation rule looks to a business' choice of a mode of operation and not to the events surrounding the plaintiff's accident. A third party's independent negligence is no longer the source of liability, and the plaintiff is not required to discover the third party's actions. The proof of a particular mode of operation substitutes for the traditional elements of a prima facie case. 251 Kan. at 709. The mode-of-operation rule is a limited exception and does not abrogate general liability rules. 251 Kan. at 710. The court cited Chiara v. Fry's Food Stores of Arizona, Inc., 152 Ariz. 398, 400-01, 733 P.2d 283 (1987), to illustrate the rule's application. "The mode-of-operation rule is of limited application because nearly every business enterprise produces some risk of customer interference. If the mode-of-operation rule applied whenever customer interference was conceivable, the rule would engulf the remainder of negligence law. A plaintiff could get to the jury in most cases simply by presenting proof that a store's customer could have conceivably produced the hazardous condition." Jackson, 251 Kan. at 710. Accordingly, a proprietor would be liable for a dangerous condition caused by a third party, absent actual or constructive notice of the condition, where, based on the mode of operation, the proprietor could reasonably foresee that the dangerous condition could regularly occur. 251 Kan. at 710.