Reynolds v. Belk, Inc.,50 Fla. L. Weekly D2691 (Fla. 5th DCA Dec. 19, 2025):

The plaintiff alleged she tripped and fell in a Belk store over an unsecured, wide-based metal stanchion. Belk moved for summary judgment relying solely on still screenshots taken from store video.

The screenshots did not show the actual stanchion the plaintiff claimed caused her fall, and they did not show her perceiving the hazard. The trial court nevertheless granted summary judgment on the grounds that the condition was open and obvious and not inherently dangerous.

The Fifth District reversed. The appellate court explained it could not rely on the full video because it was not filed in the trial court record for appeal. On this record, the screenshots did not support the trial court’s legal conclusions and did not “conclusively, clearly, and completely” negate the plaintiff’s sworn testimony that she did not perceive the hazard before she tripped. The court held triable issues of fact remained and remanded for further proceedings.