Wal-Mart Stores, Inc. v. Wright

774 N.E.2d 891 · Indiana Supreme Court · 2002

Facts

Ruth Ann Wright slipped on a puddle of water at a Wal-Mart outdoor garden corral and sued for negligence. During the jury trial, Wal-Mart's internal 'Store Manual' detailing spill procedures was admitted, and the trial court instructed the jury that a violation of these rules could be considered evidence of the degree of care Wal-Mart recognized as ordinary care. Wal-Mart appealed, arguing this instruction improperly altered the objective standard of care.

Issue

Did the trial court's jury instruction, which allowed Wal-Mart's internal manual to be considered evidence of the degree of care Wal-Mart recognized as ordinary care, incorrectly state the law by inviting the jury to apply a subjective rather than an objective standard of ordinary care?

Holding

Yes, the Indiana Supreme Court held that the jury instruction was an improper statement of law. It reversed the judgment and remanded the case for a new trial, finding the instruction incorrectly equated Wal-Mart's internal procedures with reasonable care and improperly asserted the relevance of Wal-Mart's subjective view of care.

Rule

Internal company rules or policies are admissible as evidence but do not establish the legal standard of ordinary care in a negligence action. The standard of conduct required is an external and objective one, not determined by the actor's subjective judgment or internal policies, especially if those policies exceed the objective standard.

Read the full opinion on CourtListener

Case brief last reviewed 2026-01-08. Prepared by CaseReader from the published opinion.