## Facts

- Elizabeth LaPlante attended an evening banquet at a hotel operated by Radisson Hotel Company.
- The Radisson arranged long banquet tables in parallel rows about 42 inches apart.
- LaPlante testified that a typical setup leaves about 18 inches between the table edge and the back of a seated guest’s chair, but at this banquet her chair touched the chair behind her.
- Based on those measurements, the space between chair backs in adjacent rows could be as little as about six inches.
- Because the space between rows was so narrow, waitresses could not walk down the aisle and instead passed food from person to person from the end of the table.
- There was evidence that additional open space near the entrance could have been used to allow greater spacing.
- Around 11:15 p.m., before the banquet ended, LaPlante decided to leave while the lights were dimmed.
- To get out, she moved sideways between the closely spaced chairs and tables while other guests moved their chairs to make room.
- Although LaPlante testified she could see her feet, it was dark enough that she tripped and fell, suffering injuries.
- LaPlante sued the Radisson for negligence, claiming the table-and-chair arrangement and lighting created an unreasonably unsafe condition.

## Issues

1. Must a premises-liability plaintiff present evidence (such as testimony about hotel-management customs) to establish the standard of reasonable care for banquet-room layout, or may the jury determine reasonable care from common experience based on the physical conditions shown?
2. Was LaPlante contributorily negligent as a matter of law, requiring a directed verdict or judgment notwithstanding the verdict for the Radisson?
3. Did LaPlante assume the risk as a matter of law by choosing to pass between closely spaced tables and chairs in a dimly lit room?

## Decision

- The court denied the Radisson’s motion for judgment notwithstanding the verdict and its alternative motion for a new trial.
- The court held the jury could decide, without specialized testimony about hotel practices, whether placing banquet tables and chairs so close together (and dimming the lights during the event) fell below reasonable care.
- The court held contributory negligence and assumption of risk were properly left to the jury because reasonable jurors could differ on whether LaPlante acted unreasonably and whether she knowingly and voluntarily accepted the specific risk that caused her injury.
- The jury’s verdict for LaPlante was allowed to stand.

## Legal Principles

- A hotel owes invitees a duty of reasonable care to maintain premises in a reasonably safe condition under the circumstances.
- When alleged negligence involves everyday physical conditions (such as aisle width, crowding, and lighting), jurors may apply common experience to determine reasonable care; proof of industry custom or specialized testimony is not always required.
- Judgment notwithstanding the verdict is improper when there is evidence on which reasonable jurors could find negligence and causation.
- Contributory negligence is generally a jury question unless the evidence permits only one conclusion.
- Assumption of risk requires knowledge and appreciation of the danger and a voluntary decision to encounter it; it is typically for the jury unless the facts are undisputed and point to only one result.

## Conclusion

LaPlante v. Radisson Hotel Co. upheld a jury verdict for a banquet guest who tripped and fell while exiting through an extremely narrow space between tables and chairs in dim lighting, ruling that jurors could evaluate the reasonableness of the room’s setup without specialized proof of hotel custom and that contributory negligence and assumption of risk were not established as a matter of law.


LaPlante v. Radisson Hotel Co., 292 F. Supp. 705 (1968)