A local resident has filed a lawsuit against a major corporation and its store manager, alleging severe negligence that led to significant personal injuries. James Michael Brammer lodged the complaint in the Circuit Court of the 6th Judicial Circuit in Pinellas County, Florida, on August 8, 2024, targeting Samson Merger Sub, LLC and Jane Doe.
According to the court documents, Brammer claims that he suffered substantial injuries after tripping over an uneven metal plate with protruding screws at a Winn Dixie store located at 10202 Seminole Blvd., Largo, Florida. The incident occurred on May 7, 2023. Brammer was visiting the store as a lawful guest when he encountered the hazardous condition on the floor. He asserts that both Samson Merger Sub, LLC and Jane Doe had either actual or constructive knowledge of this dangerous condition but failed to address it adequately.
The plaintiff accuses Samson Merger Sub, LLC of multiple counts of negligence under premises liability and non-delegable duty doctrines. Specifically, Brammer alleges that the company neglected its responsibility to maintain safe premises and warn customers about potential hazards. "On that same date and prior to Plaintiff's trip and fall," reads the complaint, "SAMSON MERGER SUB, LLC had actual knowledge of the tripping hazard on the floor of the subject premises." Alternatively, Brammer argues that even if there was no direct knowledge, "the tripping hazard had existed for such a length of time that... SAMSON MERGER SUB, LLC should have known of the condition."
The allegations against Jane Doe are equally serious. As a store manager responsible for daily operations and safety measures at Winn Dixie, she is accused of failing to uphold her duties. The complaint states that Jane Doe did not ensure regular inspections or communicate safety protocols effectively among staff members. "Failing to prevent reasonably foreseeable injuries and creating a foreseeable risk of harm to customers by failing to communicate and discuss safety topics at all store meetings," is one among several specific accusations listed against her.
Brammer seeks damages exceeding $50,000 from both defendants for his pain and suffering, medical expenses, loss of earnings capacity, mental anguish, permanent disfigurement, and other related losses. The complaint emphasizes that these losses are either permanent or continuing in nature.
Representing Brammer is attorney Blake R. Carl from Morgan & Morgan P.A., based in St. Petersburg. The case has been assigned Case Number: 24-0035 14-CI in front of Judge Ken Burke.