A New Jersey appeals court has ruled that three minutes is not sufficient time for a supermarket to be put on constructive notice of a hazard that injured a customer.

The appeals court affirmed dismissal of a suit filed by a customer who slipped on shampoo spilled at a ShopRite store. The panel said the judge below correctly granted summary judgment to the store in February 2019 based on a finding that the three minutes that elapsed between the spill and the fall could not create constructive notice as a matter of law.

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