LaPlante v. Radisson Hotel Co.

Elizabeth LaPlante (plaintiff) attended an evening banquet at a hotel operated by the Radisson Hotel Company (the Radisson) (defendant). The Radisson placed long banquet tables 42 inches apart. LaPlante testified that normally there are 18 inches between the edge of the table and the back of her chair; that at the banquet her chair touched the chair behind her; and if the tables were 42 inches apart and the chairs were 18 inches from the table, that left only a six-inch aisle. From the end of LaPlante’s table, waitresses passed food down person to person because they could not move down the aisle. LaPlante left at 11:15 p.m., before the banquet was over and while the lights were dimmed. She moved sideways between the tables, and various people scooted in to make room. It was dark, and although LaPlante could see her feet, she tripped and was injured. LaPlante then sued the Radisson for negligence. The jury returned a verdict for LaPlante. The Radisson filed a motion for judgment notwithstanding the verdict. The Radisson argued LaPlante offered no evidence of what reasonably prudent hotel management would do under the same or similar circumstances and that the jury should not have been allowed to speculate as to the appropriate standard of care. The Radisson also claimed the court erred in refusing to direct a verdict in its favor regarding LaPlante’s contributory negligence and assumption of risk.