In Seung Chul Na v. JP Morgan Chase, 2014 NY Slip Op 08824, the plaintiff allegedly slipped and fell on a wet floor near the entrance of the defendant’s bank. The defendant moved for summary judgment arguing that it did not create the defective condition and did not have actual or constructive notice. The lower court granted the motion and the Second Department affirmed the decision. In its decision, the Appellate Division found that the bank made a prima facie showing that it did not have constructive notice because surveillance videos showed the bank employees mopping the floor less than 30 minutes prior to the plaintiff’s accident. Accordingly, the Court was satisfied that the wet condition was not present for a sufficient period of time for it to have been discovered and remedied by the bank.

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