Howell

MEMORANDUM *

Plaintiff Martin Howell slipped and fell while working as an inmate trustee in a kitchen at the Snohomish County Jail. He and his wife and son brought this action for damages against, among others, the County, which operates the jail, and Consolidated Food Management (CFM), which had a contract to manage the kitchen. The district court granted summary judgment to Defendants. On de novo review, we affirm.

We need not decide whether, under Washington law, Plaintiff properly is classified as a licensee (as Defendants argue) or as an invitee (as Plaintiff argues). Even if he were an invitee, summary judgment was properly granted.

Plaintiff testified at his deposition that he slipped on water or grease that had been spilled on the slick floor. Under Washington law, an owner or occupier of property may be liable to an invitee for injuries arising from a transitory unsafe condition on the property if the owner or occupier (1) caused the unsafe condition or (2) had actual or constructive knowledge that the unsafe condition existed. See Pimentel v. Roundup Co., 100 Wash.2d 39 , 666 P.2d 888, 893 (Wash.1983) (stating standards).

First, the record contains no evidence that…