Judy Finley sued Ingles Markets Inc. after slipping and falling at one of their grocery stores. She asserted state-law claims for premises liability, wantonness, recklessness, and willful conduct. The district court granted summary judgment in favor of Ingles, ruling that Finley failed to provide evidence that the store knew or should have known about the water on the floor, and also ruled that she failed to present evidence that Ingles's misconduct caused her fall. The district court subsequently denied Finley's motion to alter or amend the judgment under Rule 59(e). Finley appealed, but her brief focused primarily on the issue of notice regarding the hazard, while her challenge to the causation ruling was minimal and buried within other arguments.
The court first addressed whether it had jurisdiction to review the summary judgment order. It held that Finley's appeal of the denial of her Rule 59(e) motion properly encompassed the summary judgment order under Federal Rule of Appellate Procedure 3(c)(5)(B). On the merits, the court applied the standard from *Sapuppo v. Allstate Floridian Ins. Co.*, which requires an appellant to challenge every independent ground for a judgment to obtain reversal. The district court had based its decision on two independent grounds: lack of notice (duty) and lack of causation. The court found that Finley's initial brief addressed only the duty issue. While she made passing references to causation in her brief, these were buried in summaries and did not constitute a proper challenge with supporting arguments or authorities. Because she failed to address the causation ruling in her statement of issues or provide a substantive argument against it, the court deemed her challenge to that ground abandoned.
The district court's dismissal of Finley's premises-liability claims remains in effect. This decision reinforces the strict requirement for appellants to explicitly and substantively challenge every independent ground for a summary judgment. It serves as a warning that vague or buried references to alternative grounds in an appellate brief are insufficient to preserve those issues for review.