Wal-Mart Stores East, LP v. Joseph Johnson
The Second District affirmed a jury verdict for an independent contractor's employee who was electrocuted by an ungrounded Wal-Mart junction box, holding the independent contractor defense did not bar the claim. The court applied the second exception to that defense—where the property owner negligently creates or approves a dangerous condition of which it has actual or constructive knowledge—and found sufficient evidence that Wal-Mart had constructive knowledge of the non-NEC-compliant junction box.
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