Maans v. Giant of Maryland, L.L.C

In Maans v. Giant of Maryland, L.L.C., 161 Md. App. 620, 871 A.2d 627, cert. denied, 388 Md. 98, 879 A.2d 43 (2005), Ms. Maans slipped on liquid spilled near the checkout line of a grocery store. Id. at 623-24. Lacking evidence of the duration of the spill, Maans argued that the store had constructive knowledge of the slippery condition, because the store could not show when the area had been last inspected; the store did not specifically assign an employee to look for spills; Maans fell near a cashier's work station; and the cashier had never been told to watch for hazards near her register. Id. at 630. In other words, Maans contended that constructive knowledge "may be proven by introduction of evidence that, prior to the accident, a defendant failed to make reasonable inspection of the premises." Id. at 632. The Court disagreed. The Court explained that, even assuming that Giant had failed to make reasonable inspections, Maans still "failed to produce any evidence that had Giant made reasonable inspections prior to the accident it would have discovered the water on the floor in time to prevent the accident." Id. at 632.