Wood v. Woolfolk Properties, Inc.

The primary issue in this premises liability case is whether the circuit court erred by admitting evidence pertaining to the absence of prior accidents. Finding error in the circuit court’s judgment, we will reverse.

I

This appeal arises out of an accident that occurred on the evening of May 20, 1994, in front of Ruth’s Chris Steak House (Ruth’s) located in Chesterfield County. The plaintiff, Edna Wood (Wood), and several members of her family ate dinner at the restaurant that night. After finishing their dinner, the Wood party prepared to leave the restaurant. While Wood’s son went to the…