A harrowing slip-and-fall incident has led to a lawsuit that could set a precedent for tenant safety and landlord responsibilities. Richard Manfredi filed a complaint on August 2, 2024, in the Circuit Court of Pinellas County, Florida, against Rodney S. Daniel and Heather R. Norton, trustees of the Rodney Daniel and Heather Norton Revocable Trust dated August 7, 2014.
According to the complaint, Manfredi was a month-to-month tenant at a property located at 3411 Cambria Court in Safety Harbor, Pinellas County. The property is owned and managed by Daniel and Norton through their trust. On November 9, 2023, while moving out of the rental property with permission from Daniel to retrieve his belongings, Manfredi stepped on ball bearings scattered across the floor. This caused him to fall violently onto his left knee and hand, resulting in severe injuries including damage to his neck, left shoulder, left knee, and lower back.
Manfredi's complaint alleges that the ball bearings were negligently placed or left on the floor by either the defendants or their agents. The gray color of the floor made these ball bearings nearly invisible to Manfredi. He asserts that this created a "slip and fall hazard" that should have been known or discovered by reasonable care from the defendants or their agents.
The plaintiff contends that the defendants breached multiple duties under Florida law: maintaining a safe environment for tenants; correcting hazardous conditions; and warning tenants about potential dangers. Specifically, he accuses them of failing to properly manage and inspect the premises to ensure safety. As a result of these alleged breaches, Manfredi claims he has suffered permanent injuries leading to extreme pain and suffering, disability, mental anguish, loss of earnings, diminished earning capacity, and ongoing medical expenses.
Manfredi seeks damages exceeding $50,000 exclusive of costs and interest. He also requests a jury trial for all issues triable as such.
Representing Manfredi are attorneys Tim Ingram Jr., Megan E. Ingram from Ingram Injury Law based in Clearwater, Florida. The case has been assigned Case Number 24-003429-CI.