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here
Shopper sues for $750K
after being hit by trolley
From: The
Daily Telegraph
August 15, 2007
REBECCA Tormey
was picking up fabric softener at a Sydney supermarket
when two men "skylarking" knocked her over with a
shopping trolley.
The back injury she
suffered was aggravated by a sneezing episode, leaving
her temporarily unable to walk, the NSW District Court
heard yesterday.
The mother-of-two is
suing Coles supermarkets for negligence, seeking up to
$750,000 in damages over the accident at the Gladesville
store in February 2003.
Click here to read the full
article on the website
Alternatively, you can
copy and paste this link into your browser:
http://www.news.com.au/story/0,23599,22245952-2,00.html
Council
Facilities - They Come At A Cost
- from
http://www.gdlaw.com.au/Services/December06.pdf
At
what cost does a Council provide facilities to the public? If facilities are
provided and an accident happens, can a Council be held liable? If so, in what
circumstances? What duty does a Council owe to members of the public and is the
duty more onerous when the young are involved? Interesting issues! Balancing the
consequences of risk and reward in providing facilities for the public will
always be an issue for Councils. The Court of Appeal has recently visited these
issues in a judgment that has delivered more than $1.6 million in damages to a
young girl injured on a BMX track on Council land.
Rhiannon Rigby, a 13 year old, was riding her bicycle along a BMX track situated
in a sporting complex at Albion Park. The sporting complex was located on
community land and the track was open to the public. She cycled down the
starting ramp, built up speed in an attempt to ride over a speed hump and as she
took off over the speed hump her bike became airborne and she fell to the
ground. Rhiannon suffered brain damage as a result of the accident and
successfully brought proceedings in the Supreme Court against Shellharbour City
Council and the BMX Club. The Trial Judge originally found that by failing to
fence off the starting ramp to prevent it from being used by inexperienced
riders, both the Council and the Club were in breach of a duty owed to Rhiannon.
Rhiannon was awarded in excess of $1.8 million. Both the BMX Club and the
Council appealed. The Council was the owner and occupier of the whole of the
sporting complex which was a substantial area of land, much of which was heavily
wooded and included a football and hockey field, tennis courts, cricket nets and
changing sheds. There were numerous unsealed trails running through the area
which were mostly used for bicycle riding. A BMX track occupied an area of about
100 metres by 50 metres wide within the sporting complex. The BMX track had been
designed and built by the BMX Club. Development consent had been granted by the
Council as the development authority. The Council had supervised the
construction of the works and provided labour and machinery to undertake the
works. The Council had overall management and control of the sporting complex
although the ongoing management of the track was the responsibility of the Club.
The BMX Club’s right of use of the track was granted by means of an annual
approval from the Council for the use by the Club from Monday to Friday. The
track itself was located on land zoned community land and Council approval was
necessary to erect any fencing on any part of the BMX track. The Court of Appeal
was called on to determine whether or not the Trial Judge was right in
concluding that both the Council and the BMX Club were negligent. The amount of
damages was also challenged as was the respective apportionment of
responsibility between the BMX Club and the Council and Rhiannon. The Court of
Appeal upheld the original Judge’s findings on negligence. When looking at
issues of negligence of an occupier, in this case the Council, it is necessary
to identify whether there is a general duty of care and in addition it is
necessary to have regard to the content of the duty of care owed to a person in
a particular case. The content of the duty of care may be determined by
reference to the kind of damage suffered and the class of which an injured
person is a member. The age of Rhiannon was
relevant as was her inexperience in BMX. The Court stated:
“In
determining the duty of a statutory authority, control is an important
consideration, particularly as a statutory authority does not necessarily have
the same level of control over access to land or premises in question as does a
private occupier.”
The
fact that the sporting complex was managed by the Club did not abrogate the
Council’s duty of care nor did it confine its generalised duty of care that was
owed to those persons that used the park.
The
Court concluded that the question of obviousness of risk goes to issues of
breach of duty rather than whether there was a duty of care. Even if obviousness
was relevant to duty, the fact that there was a risk of injury in Rhiannon’s
case called for a response. The question of what response was called for went to
the question of breach of duty and the obviousness of the risk was not
determinative of the breach. The Court of Appeal held that the class of persons
who the Council owed a duty to take reasonable care were all persons who were
likely to use the track other than under the supervision of the Club and this
included Rhiannon.
The
Court of Appeal held that the Council ought to have taken reasonable steps to
avoid injury to inexperienced riders by fencing off the starting pad and ramp to
prevent it being used by such riders. The Trial Judge was correct in that
finding. The Court of Appeal also held that Rhiannon was not engaged in the
sport or recreation of BMX racing such as to undertake the inherent risks of the
activity. The Council was not entitled to expect an entrant of Rhiannon’s age to
exercise a degree of care comparable to that of an adult with a similar lack of
experience.
In
relation to the BMX Club, the Court of Appeal found that reasonable members of
the community in the Club’s position would consider that the risk required
preventative action, namely, fencing off the starting pad and ramp. When
considering issues of apportionment of liability between Rhiannon, the Council
and the Club, the Court of Appeal concluded that the Council and the Club were
the most culpable parties. The Court concluded the Club, having designed and
constructed the track, and the Council, having had day to day management of the
track and being the consent authority, should equally share responsibility for
the accident. The original Trial Judge had concluded that Rhiannon was 20% to
blame for the accident. The Court of Appeal agreed.
A
major damages claim to deplete Council funds available to provide facilities to
the community. A fair result? Certainly for the young lady injured but was too
much responsibility imposed on the Council and the Club? Councils continue to be
exposed to significant claims where members of the public are injured utilising
facilities which have been supplied or made available for the benefit of the
community. This judgment sounds a further warning that Councils must take heed
of the possibility that inexperienced and young persons may use facilities made
available to the public. Councils must take steps to protect those of tender
years from misusing facilities. The relatively minor cost of fencing in this
case weighed against the catastrophic injury justifying the Court finding that
more should have been done by both the Club and the Council to avoid the risk of
injury and eliminate a substantial claim for damages.
KIDS
Each year
about 300
Australian children (aged 0-14 years) are killed and 60,000 hospitalised by
unintentional injuries – the kind often referred to as ‘accidents’. A large
proportion of these accidents occur at home or on the road but a significant
number occur in public places, venues and other areas controlled by others. The
cost of these accidents is often significant in both financial and emotional
terms. Negligence claims involving children are difficult and expensive to
defend and most cases are settled out of court.
Unless we are directly involved, we can never appreciate how
devastating these incidents are for not only the families but also for
witnesses, for those who's negligence may contributed to the accident and for
emergency services personnel who attend the scene.
A few recent examples:
-
A 5 year old boy who
travelled up the outside of an escalator in a shopping centre, fell from the
top and died from massive head injuries
-
A 3 year old boy shopping
with his mother who was carrying his baby sister and let go of his hand
briefly to pick up an item from a shop shelf. He instantly ran out the door
and out onto an external verandah wanting to look at a reversing truck. He
climbed the balustrade and fell 3m onto the roadway. He suffered a fractured
skull and potential brain damage. Luckily he just missed being run over as
well. The whole event took only seconds.
-
An 8 year old boy who
climbed on outdoor furniture on the balcony of a holiday apartment and fell
6 storeys to his death
-
An 11 year old girl who
drowned when her hair became trapped in a spa inlet at a holiday resort
-
Child severely burned by a
log falling out of a hotel fire place
-
A 4 year old girl who
pulled a display onto herself in a department store and was crushed to death
-
A 2 year old boy fell out
of a shopping trolley and suffered permanent brain damage.
-
A 3 year old girl who
climbed on a chair in a shopping centre food court and fell over the
balustrade to her death
-
Baby who rolled off a
change table in a shopping centre mother's room and suffered multiple
fractures
-
A 12 year old boy fatally
electrocuted when he stood on broken electrical conduit beside a Motel pool.
-
A 2 year old boy who had
his finger amputated by the tread comb of an escalator
-
Mother and 3 year old
entered a workshop to collect the father after work. A vehicle being worked
on at the time on fell on the child causing fatal injuries.
-
A 5 year boy climbed on a
wagon wheel displayed in the beer garden of a pub. The wheel fell on to the
child and he received fatal injuries.
-
A 3 year who pulled over an
electric jug located on a complimentary tea & coffee table in a restaurant
and suffered severe burns.
The most common response to these incidents is: "where were
the parents" but in most cases they were normal loving parents who were just
momentarily distracted or put their trust in someone else to provide and
inherently safe environment.
Many of these can be easily prevented by simple
means.
-
Educate staff regarding the
risk that the workplace or their actions may pose to children
-
Conduct regular documented
inspections of the venue/workplace keeping in mind the often the
adventurous, inquisitive and unpredictable actions of young children.
-
Regular (at least daily)
inspections of playgrounds, high chairs, structures, furniture and other
areas or items used by children
-
Guard fire places and other
potentially hazardous situations
-
Warning signs, disclaimer
notices and parental supervision signage
-
Restrict access to work
areas
-
Remove all “attractive
nuisances”
-
Take action to control
known activities such as skateboarding in carparks.
-
Install earth leakage
circuit breakers and regularly inspect electrical systems
“BACK TO BASICS”
Statements of claim in liability cases usually
always contain a long list of allegations to the effect of:
The following list is not exhaustive but covers
the basic physical risks (and common causes of injury and subsequent claims)
found in retail, hospitality and other public venues along with some suggested
controls.
-
Lighting
Otherwise obvious hazards and risks can be very difficult to discern in areas
which are inadequately lit. Inadequate lighting also increases the risk of
violence to patrons, customers and staff. Regular hazard inspections
should be conducted externally after dark and in all internal areas without
natural lighting to ensure that adequate lighting is provided and operating
correctly. A light level audit should be conducted in larger venues and external
areas by a suitably qualified consultant. Replace damaged fittings and blown
bulbs as soon as possible. Check the operation of automatic sensors. Adjust
timer switches for seasonal change and daylight saving. Similarly, too much
light in the form of glare, bright spot lights and sunlight can impair vision
significantly.
-
Steps & Stairs
Falls on stairs often result in very serious injury and substantial claims. Many
people just do not see the stairs particularly if they are of similar colour or
pattern to the landings. The edges of steps should be highlighted by suitable
means as such as non-slip strips or paint in a contrasting colour. The noses of
carpeted stairs can become smooth and slippery over time. Best advice is to
install metallic extrusions, preferably with rubber non slip inserts, to the
nose of all carpeted steps. This will also significantly prolong the life of the
steps. All steps and stairs should be fitted with at least 1 easily accessible
handrail.
-
Uneven Paths
Pedestrian paths should be kept free of slip and trip hazards such as large
cracks, loose material (eg gravel, garden mulch), vegetation (tree roots and
overhanging branches), uneven surfaces, uncovered drains, pot holes, subsided
pavers, rotted timber boards, moss, advertising signs etc. Pathways should be
well lit at all times. Any trip hazards which cannot be removed or repaired
should be well highlighted with bright yellow paint or other suitable means.
Kerb entry ramps are a common cause of injury and should be well highlighted.
-
Toilets
As well as for hygiene and customer comfort reasons, toilets should be regularly
inspected for water spills, inadequate lighting, leaking soap dispensers,
overflowing waste bins, taps left running and undesirable activity. A toilet
checking log book is highly recommended, traditional check cards on the back of
the door tend to be stolen or defaced.
-
Spills
A normally safe floor surface can become extremely hazardous after a spill.
Staff should be on constant look out for spills of food, drink, oils, broken
glass, rubbish and other items. Spill procedures should be implemented and
include notification (ie two radio in large venues), provision of staff to stand
over the spill, warning signage, wet mopping and dry mopping. It may be of value
to keep a spill log to determine common locations, types and cause of spills
over time.
-
Furniture
There have been some serious injuries caused by furniture which is in poor
condition. All furniture should be regularly inspected for loose screws, sharp
edges, improper balance, splinters, broken components, bent legs, torn fabric,
missing rubber feet etc. Pay particular attention to children’s high chairs
which should all comply with Australian Standards and be fitted with a safety
harness. Outdoor furniture can become brittle over time with exposure to UV and
should be regularly replaced.
-
Car parks
Car parks are not normally inspected as often as they should be. Any wheel stops
should be painted in a contrasting colour, highlight any impact points (light
poles, kerbs, bollards etc) repair pot holes, clean up oil spills, ensure
adequate lighting, trim vegetation, install appropriate signage (speed signs,
direction indicators, pedestrian crossing), ensure drain covers are in place and
level, inspect prior to opening every morning for broken glass and other
overnight activity.
-
Forklift trucks
There have been a number of serious incidents in recent years involving third
parties (ie customers and delivery drivers etc) being injured by mobile
equipment, particularly forklift trucks. The owners/operator’s Public Liability
Insurance policy may not generally cover the cost of resulting claims where the
equipment should have been registered and hence a claim made on the Compulsory
Third Party Insurance Policy (CTP) under the Motor Accidents Act or similar.
Legislation varies in each State and has recently been updated in some to
broaden the definition of a public road. Generally, any vehicle or mobile plant
(including forklifts, sweepers, “welcome wagons”, trolley tractors & trailers
etc) operated in a publicly accessible area (ie car parks, loading docks,
driveways, footpaths etc) should have appropriate registration and CTP. This is
usually known as Conditional or Restricted Use Registration.
You should ensure that all vehicles are appropriately registered when operating
on this site. All operators must have appropriate licenses and a record of this
should be kept on file.
Also additional controls should be in place, particularly for forklifts, this
could include speed governors, reversing alarms, flashing amber lights, warning
signage, mirrors (on and off vehicles), restricting usage to outside of trading
hours and barricading of operating areas.
-
Loading/back areas
Loading docks and other non public areas are sometimes not given the same
attention as “front of house areas”. Injury to contractors or delivery drivers
can result in large claims. These areas should be regularly inspected, clean up
spills immediately, regularly remove waste and packing containers, highlight
steps, install hand rails, repair any damaged structures, provide non slip
surfaces, remove or highlight trip hazards, discourage customers from parking in
the area, ensure adequate lighting, provide adequate manoeuvring space, indicate
any low height areas, highlight impact points.
-
Balustrades and raised areas
There have been a number of fatalities, some
involving children, caused by patrons falling over balustrades or from raised
areas. Furniture and other climbable objects must be kept well clear of
balustrades at all times. Balustrades should be correct height and free of climb
points and large openings. Balustrades and railings should be inspected
regularly for structural adequacy. Building Code only requires a balustrade
where a person could fall more than 1m. However, all raised areas should be
protected where practical.
-
Signage and displays
All advertising signage should be well secured and placed out of pedestrian
paths. A-frame type signs have been banned now from most large shopping centres.
Normally a license is required from Council to display signage on footpaths.
Likewise with any displays out side the shop. These should be safe, well secured
and specifically covered by your insurance policy.
LIABILITY FOR IT
CONSULTANTS & WEB DESIGNERS
Recent Cases
The landmark decision of Houghton v Arms, handed down
on 13
December 2006, in the High Court specifically concerned employees of a website
design company, and therefore is of special interest to the IT industry.
Mr Arms set up a company
"Australian Cellar Door" to sell wine from small wineries via a website. His
plan was that direct sales would attract lower sales tax and avoid the 30 per
cent retail margin.
He contracted “WSA Online” to
set up the website. Mr Haughton and Mr Student worked for WSA and was described
as the "guru of interactive website design and development". In January 2000
Haughton told Arms about "ANZ e-Gate" which would be "perfect" for the
requirements of electronic transactions over the internet. Customers could pay
by credit cards with payments going directly to the wineries. Arms was told that
wineries could be added to the web site by simply filling in a form and paying a
small set-up fee. Arms travelled around Australia and signed up 30 small
wineries based on this advice.
ANZ told WSA in February 2000
that in fact, all the wineries would have to go through a full credit card
merchant facility process including producing profit & loss statements. WSA did
not tell Arms about this until June 2000 when the website was only 5 days from
going live and the merchant facilities could not be arranged in that time.
To reserve his credibility,
Arms then had to convert Australian Cellar Door into a retailer, pay the higher
sales tax and retain a 5% commission from wineries on the sales. He then
operated at a loss for 12 months before changing the structure of the business
to now make a profit. He was awarded $58,331 plus costs.
Another interesting point about
this case was that not only was WSA Online sued but their employees Mr Haughton
and Mr Student were sued for making false representations.
Best Practices – IT Consultants, Web site developers
-
Do not make overt claims in
advertisements, online or elsewhere, about your products and services
ability to dramatically reduce costs, increase productivity, improve sales,
or increase website traffic overnight as a result of using your services.
-
Properly identify the
client and who has authority to instruct you or be the primary contact for
issues and guidance.
-
Don’t regurgitate old
contracts. Agreements should be prepared individually for each new client
and checked thoroughly by a legal professional. Ensure that paper copy
contracts are in place for all major contracts rather than on-line proposals
or emails.
-
All relevant milestones
and dates should be clearly stated in the contract.
Unless there
is a clear written agreement, the client and IT consultant can have
different interpretations of delivery dates, the development timetable,
responsibilities and the liability of the parties for any delays.
-
Ensure that
the contract documents aspects such as handover, training, testing, support,
domain name purchase, hosting, search engine listing and optimization,
traffic reporting, security, updating, image creation, contingencies,
support for when problems occur etc
-
During initial meetings
with clients, make it clear that implementing a new software package or
establishing a successful internet based business takes time, can be risky
and there will unlikely be an immediate return on capital invested.
-
Ensure that you have
adequate staff or pre-selected contractors for specialised or “overflow”
situations.
-
Hold regular, documented
progress meetings with the client, do not rely solely on email
correspondence. Emails tend to written hastily and use informal language.
Document all meetings and telephone calls in detail.
-
Disclaimers in
the written agreement should state the fact that it cannot be warranted that
the software is “bug free”. Some inexperienced clients who are not familiar
with software development may expect to receive a perfect product on the
delivery date.
-
Particularly
for commercial or merchant web sites, the web site developer should also
attempt to limit warranties as much as legally possible otherwise you could
be liable for large claims and losses caused by server unavailability,
privacy violations, accessibility, data loss, viruses, payment system
failures and security breaches.
-
The web site
owner should consider the use of trade marks on the web site and
infringement of any copyright laws in regards to images and information. The
fact that a trade mark is registered in Australia, does not mean that it
will not infringe other parties’ trade marks outside Australia. Also check
whether the domain name used for the web site infringes any intellectual
property rights. The US has seen many recent cases of parties registering
domain names which suggest an affiliation with a well known corporation
which they hope to sell to the corporation in question.
-
If the client
provides any materials for inclusion in the software or web site, an
intellectual property indemnity should be obtained from the client.
-
Avoid using hidden key
words or metatags in websites which contain trademarked words or slogans or
that do not honestly represent the clients products or services.
-
Undertake regular data back
ups and virus scans of your own computer systems.
-
The
development and maintenance of IT systems or web site may involve the
disclosure of confidential information like product releases and other
business plans. Ensure that you and all of your staff
-
Before reusing any part of
new software or web site designs for other customers ensure that this is not
in breach of any contractual clauses with the original client.
-
Carefully select all of
your employees, conduct thorough reference checks, provide regular training
and performance reviews. Make them fully aware of all contractual
arrangements and confidentiality clauses.
-
Most importantly, be
completely transparent at all stages of the project. Notify the client
immediately of any issues of concern and carefully document their response.
Slip and Fall Accidents - a Brief Overview
Author:
Arthur Gueli
Slip and fall accidents are quite common and these types of
personal injury claims go to insurance companies regularly. And why not? Most of
us walk more often than we drive. And when we're walking we encounter as many,
if not more, obstacles than when we're in a car.
If you slip and fall and get injured, you'll go through the same process as if
you were in a car accident. You need to prove liability, which means finding
negligence and causation. But unlike car accidents, the signs that someone was
actually negligent aren't always clear cut.
When driving a car there are laws and rules for how you get around. This means
your duty of care is largely defined by very specific vehicle codes. There are
very few laws on the books that regulate how anyone has to walk. In fact, the
only laws that really exist for walking are to protect you from getting hit by a
car.
Therefore, liability for slip and fall cases is hard to determine. It almost
always comes down to finding whether or not someone else was acting reasonably.
The phrase 'within reason' comes up in the law a lot, making it difficult to
deal with personal injury court cases. It's a very subjective thing, and people
rarely agree on what qualifies.
Common reasons for a slip and fall injury are slippery surfaces, unseen objects
and worn or torn floors or floor coverings. These all present similar liability
issues. How long was the surface in that condition? If it's slippery due to
spillage, who spilled? If there was an object that has been tripped over, how
did it get there?
If you're injured from a slip and fall on someone else's property, whether it be
public, private or commercial, you need to answer these kinds of questions.
If you believe something other than bad luck is the cause, then proceed as you
would with any other kind of accident. Examine the environment. Talk to
witnesses. Ask questions and take pictures.
Because liability in these cases will most likely come down to whether or not
the other party was acting reasonably, it's the presentation of your argument
that will make or break your case. So when you finally do approach the insurance
company, stress any evidence you know could sway a judge later on.
Article Source:
http://www.articlesbase.com/law-articles/slip-and-fall-accidents-a-brief-overview-198672.html
About the Author:
About author :
Arthur Gueli works with his brother Charles (a licensed personal injury
attorney) teaching injured people how to protect their rights and obtain fair
compensation for their damages. Learn more about liability in traffic accidents
(and how to make it work in your favor) at this page on their information-packed
website:
http://www.injury-settlement-guide.com/personal-injury-lawsuits.html
Injury-Settlement-Guide.com
General Liability in Accidents Involving Children
Author:
Arthur Gueli
General liability rules vary from state to state when minors
are involved, but they do tend to give children the same basic rights. This is
true both for accidents caused by children and accidents resulting in the injury
of a child.
If a child is injured (in any US state) they are given just as much right to
compensation as if they were an adult. All the same general liability rules
apply to them as if it were an injury to an adult. The only real difference is
that the minor will not likely be paying the medical bills. So the parent or
guardian has their own right to seek a settlement for the medical expenses they
paid on behalf of the child.
A child is also able to claim damages for pain and suffering and is entitled to
money for lost future earnings (if it can be shown the permanent injury will
effect that).
Because the child will be unable to represent themselves in the negotiation
process most states require a judge to approve the settlement (to make sure the
child's best interest are being looked after).
Once you've agreed on the settlement amount the insurance company will likely go
out of their way to help you through the approval process. It's in their
interest as much as yours to make sure this approval goes off without a hitch.
If this isn't done properly the child could, in theory, get a lawyer and sue for
more money at a later date.
Children Causing Injuries:
When the accident is caused by a child the general liability rules become
tricky. There are only a few defined ages when a person is old enough to be
legally responsible for something, so it becomes a judgment call in most cases.
If the child is very young though, usually below eight years old, it is
generally accepted that duty of care cannot apply to them. Children at that age
aren't likely able to determine what a careful action is and therefore can't be
held liable for an accident they cause. If your personal injury resulted from
someone in this age group you can still try to hold their parents accountable
for not controlling their children.
Liability can generally be placed on children that are older than that. To do
this you have to show that they were not as careful as most others in their age
group would have been. Once a minor reaches the mid-teens they are almost always
considered old enough to be held liable. This is especially true once they begin
driving.
Unfortunately, no matter how negligent a minor is, they won't likely be insured.
In a car accident scenario, they'll be insured through their parents' policy and
this is where you'll seek damages from. In other accidents you can often go
through the parents' homeowners insurance because the child is likely a resident
at that address.
There are general liability rules in place that let you go one step further. In
most states, if you can prove that the child displayed gross negligence in
causing your injury but there is no insurance to claim from, you can pursue a
lawsuit directly against the child. This will likely be a lengthy and complex
legal battle so you'd want legal council and you would only want to do it when
the damages are high. The result of a win would be the minor having to pay you
money once they turn eighteen and get a job.
Article Source:
http://www.articlesbase.com/law-articles/general-liability-in-accidents-involving-children-202203.html
About the Author:
About author:
Arthur Gueli works with his brother Charles (a licensed personal injury
attorney) teaching injured people how to protect their rights and obtain fair
compensation for their damages. Learn more about the rules of liability (and how
to make them work in your favor) at this page on their free educational website:
http://www.Injury-Settlement-Guide.com/personal-injury-lawsuits.html
Injury-Settlement-Guide.com.
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