According to Florida law, supermarkets are required to have an intensive floor inspection program:
First, we conclude (a) there are no genuine issues of material fact on the issues of adequate inspection and constructive notice, and (b) the defendant is entitled to a judgment as a matter of law on these issues. Unlike a supermarket or retail sales store, the hospital hallway where the subject accident happened did not have nearby food, sales products, or other substances on shelves or anywhere else in the hallway which might drop to the floor and thus create a dangerous condition thereon. This being so, an intensive floor inspection program to discover foreign substances on the floor was, as a matter of law, unnecessary. Moreover, the defendant’s employee had cleaned the subject hallway at least twelve hours before the subject accident, and the defendant had a routine inspection system in place, although at unstated intervals, to discover foreign substances in the subject hallway. Beyond that, we are not persuaded by the claim that a shoe mark in some clear liquid discovered about a foot away from where the plaintiff slipped and fell raises a triable issue as to whether the liquid on which the plaintiff slipped and fell was there for sufficient length of time to give the defendant constructive notice of its presence. Unlike Winn Dixie Stores, Inc. v. Guenther, 395 So.2d 244 (Fla. 3d DCA 1981), and Zayre Corp. v. Bryant, 528 So.2d 516 (Fla. 3d DCA 1988), (a) there were no extensive track marks through the liquid in question, but only a single shoe mark, and (b) the accident occurred in a hospital hallway [as opposed to a supermarket or retail store] where, as a matter of law, an intensive floor inspection program was not required to discover spilled liquids. See Winn–Dixie Stores, Inc. v. Marcotte, 553 So.2d 213, 215 (Fla. 5th DCA 1989); Emmons v. Baptist Hosp., 478 So.2d 440, 442 (Fla. 2d DCA 1985), rev. denied, 488 So.2d 67 (Fla.1986).
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