In the trial of a personal injury claim involving a slip and fall accident in a stairway, the injury lawyer for the plaintiff (the person who was injured and who filed the lawsuit) should address the following issues when presenting the case to the jury:

Dimension and measurements of the stairway

  1. Diagram showing each feature of the stairway and contiguous areas
  2. Chart with measurements of the risers and treads of each step within the stairway
  3. Measurements of the height and configuration of handrails
  4. Charts containing coefficient of friction or slip resistance data


  1. Wide view photographs depicting the stairway and surrounding areas
  2. Middle view photographs depicting the placement of handrails, guardrails and other architectural features
  3. Close up views of the surface texture of the stair treads, non-skid abrasive strips, handrail cross-section, etc.
  4. Views of the stairway from the direction in which the plaintiff was walking
  5. Views with markers where the plaintiff indicated the fall occurred, where she came to rest and other relevant landmarks
  6. Where lighting is an issue, the location of nearest light fixtures and switches
  7. Close-up views of light fixtures, including bulb wattage


  1. Enabling ordinance, in which local government adopts model building code
  2. Copies of each of the building code sections covering stairways and exits
  3. Copies of any relevant ASTM, ANSI or OSHA codes or standards
  4. Copies of emergency medical response reports


When a personal injury lawsuit is filed, the lawyers for each party engage in a fact-finding process called “discovery.” The discovery process includes written requests to produce documents (e.g., medical records) and “depositions.” A deposition is an oral question/answer session in which the lawyer for one party takes the testimony, under oath, of witnesses for the other party. Discovery materials that may be useful in a stairway slip and fall case include:

  1. Deposition testimony of building owner
  2. Deposition testimony of property manager
  3. Deposition testimony of opposing expert
  4. Deposition testimony of person most knowledgeable regarding inspection and maintenance
  5. Depositions of emergency medical personnel responding to accident