MIAMI HUB – QPWB attorneys, led by Partner Trelvis Randolph with key support from Associate Karla Alberte Gonzalez, secured a decisive victory in a high-exposure negligence suit involving a minor’s alleged injury at a recreational trampoline facility. Through a strategically crafted Motion for Summary Judgment, the court granted full dismissal of the case, awarding $0.00 in damages despite the Plaintiff’s claims of multi-million-dollar liability.

Overview of the Case

The Plaintiff filed a premises liability lawsuit on behalf of her minor son, alleging that he sustained a leg fracture while jumping from a raised platform into a foam pit at the defendant’s trampoline park in 2021. The Plaintiff, who is also the natural guardian of the minor, asserted that the facility failed to maintain safe conditions, pointing to extensive medical treatment and recovery costs in support of a multi-million-dollar damages claim.

QPWB represented the owner of the recreational facility and centered its defense on both procedural precision and the lack of any admissible evidence of negligence. The minor child was chaperoned by other adults, who could not explain how the incident occurred and has since broken off contact with the Plaintiff mother. The Plaintiff was not present at the time of the incident and could not describe how the injury occurred. The Plaintiff’s position was further weakened by her inability to secure testimony from the adult chaperones who accompanied the child. The defense team seized on these critical gaps and filed a motion for summary judgment under Florida Rule of Civil Procedure 1.510, which went unopposed by the Plaintiff.

Key Difference-Makers

• Trelvis Randolph – Partner
  
• Karla Alberte Gonzalez – Associate

Claims Made Against Our Client

• The Plaintiff alleged that the client, owner of the trampoline facility, failed to maintain a safe recreational environment, resulting in the minor’s leg fracture.
  
• Plaintiff claimed that this matter was worth millions due to the extensive medical bills accumulated during the medical treatment and recovery of the Plaintiff.
  
• Plaintiff is asserting negligence solely based on the occurrence of the incident on the client’s premises, without presenting supporting evidence of actual wrongdoing.

Defense Strategy

From the outset, QPWB pursued a focused and efficient strategy designed to secure early resolution of the case. The defense argued that the Plaintiff had no evidence to support a claim of negligence and that the injury was an inherent risk associated with the use of trampoline park equipment—a risk the Plaintiff had previously acknowledged during prior numerous visits to the facility.

The Motion for Summary Judgment highlighted key weaknesses:

• The Plaintiff did not witness the incident.
  
• Adult chaperones were unable to provide relevant testimony.
  
• No surveillance footage, documentation, or witness testimony could establish negligence.
  
• The plaintiff missed the 40-day deadline to respond to the motion under updated Florida Rule 1.510, which mandates timely response to summary judgment motions.

Impact on Final Outcome

The court’s granting of Summary Judgment resulted in a complete dismissal of the case, absolving the trampoline park and owner of any liability and awarding no monetary damages. This not only shielded the client from protracted litigation but also reinforced the effectiveness of Rule 1.510’s revised procedures in efficiently disposing of meritless claims.

It is imperative to know the rules of civil procedure and adhere to its timelines and requirements. The new rules for MSJ went into effect on Jan. 1, 2025 and applies to all MSJ's filed after that time.

Unique Aspect of the Case

A particularly unique element was that the minor plaintiff had frequented the facility numerous times prior to the injury, including under the supervision of the same parent who brought the lawsuit. Multiple visible warnings about the risks of trampoline activity were posted throughout the premises, further reinforcing the inherent risk defense.

Predicting the Future

This case highlights QPWB’s proficiency in identifying procedural and evidentiary weaknesses early and using them to secure favorable outcomes. The win serves as a model for defending recreational facilities and businesses in premises liability actions, particularly those involving inherent risk arguments and Summary Judgment opportunities under Florida’s updated rules. It further demonstrates the firm’s dedication to early, cost-effective case resolution—an approach that will continue to benefit future clients facing similar exposure.

Key Actions in This Case

• Early Filing of Motion for Summary Judgment: Drafted and filed before the Plaintiff could gather testimonial support or respond effectively.
  
• Procedural Leverage: Plaintiff’s failure to comply with FRCP 1.510 deadlines was used to secure judgment.
  
• Evidence-Based Defense: Highlighted absence of any proof of negligent action by the facility or its employees.
  
• Inherent Risk Doctrine: Reinforced that injuries stemming from trampoline use are assumed by legal guardians.
  

About QPWB

Quintairos, Prieto, Wood & Boyer, P.A. is the largest minority and women-owned law firm in the United States. With 48 offices across the country and over 100 areas of practice, QPWB provides comprehensive litigation, regulatory, and corporate representation to clients across a wide range of industries.