Revolving Door Injuries: Entrapment and Crush Claims in Georgia

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A person hurt by a revolving door in Georgia can look to two main defendants, and a different statute governs each: the owner or occupier of the building under the premises statute, and the maker of the door under the product statute. The claim against the owner turns on what the owner knew about the door and what the injured person knew. The claim against the manufacturer turns on the door’s condition when it was sold and on a ten-year period that runs from the first sale.

The Owner or Occupier

An owner or occupier who invites the public in owes ordinary care in keeping the premises and approaches safe (OCGA 51-3-1). Under Robinson v. Kroger Co., 268 Ga. 735 (1997), an invitee must show the owner’s knowledge of the hazard and the invitee’s own lack of knowledge despite ordinary care.

Whether the door counts as a fixed or a moving condition shapes that comparison. For a fixed condition, a person who has used it safely before can be treated as knowing its hazard as well as the owner: in Meadows v. Dollar General Store, 371 Ga. App. 695 (2024), a customer hurt while pulling a defective sliding door closed had come through it without trouble earlier that day, and the Court of Appeals affirmed summary judgment for the store. A condition that moves is treated differently. In Johnson v. LT Energy, LLC, No. A23A0240 (Ga. Ct. App. June 27, 2023), a store entrance mat that could slide was held not to be a static condition, so the rule about a customer’s earlier safe passage did not apply; the owner knew the mat was unsecured, and whether the mat was a hazard and whether the customer used ordinary care went to a jury. Which side of that line a revolving door falls on is a question an owner and an injured person can contest.

The Manufacturer

OCGA 51-1-11(b)(1) holds the manufacturer of personal property sold as new, directly or through a dealer or another person, liable in tort without regard to privity to a person injured because the door, when the manufacturer sold it, was not merchantable and reasonably suited to its intended use and that condition proximately caused the injury. The Supreme Court of Georgia treats a defect as arising in manufacturing, in design, or in marketing or packaging (Banks v. ICI Americas, Inc., 264 Ga. 732 (1994)). Under OCGA 51-1-11(b)(2), no action under that subsection may be brought for an injury more than ten years after the door or other product that caused it was first sold for use or consumption.

Owner, Manufacturer, and Servicer Together

Georgia divides damages among those who are liable by their percentages of fault, and each pays only its own share, without joint liability or contribution (OCGA 51-12-33(b)). For example, imagine a revolving door that keeps turning after a child’s hand is caught because its safety sensor failed. The claim against the manufacturer asks whether the sensor design or the unit as sold was defective; the claim against the owner asks what the owner knew about earlier malfunctions; and a company that serviced the door is not liable as a manufacturer in strict liability, although the product seller statute does not itself decide other theories against it (OCGA 51-1-11.1(b), (c)). If a jury assigned 55 percent of the fault to the owner and 45 percent to the manufacturer on $100,000 in damages, the owner would owe $55,000 and the manufacturer $45,000, each separately.

Frequently Asked Questions

Does the ten-year limit bar every claim against the maker of an old door?
It also applies to negligence claims against a manufacturer, except claims for products causing a disease or birth defect and claims based on conduct showing a willful, reckless, or wanton disregard for life or property, and it does not relieve a manufacturer of the duty to warn of a danger once the danger becomes known (OCGA 51-1-11(c)).

Who counts as a “product seller” rather than a manufacturer?
A business that, among other things, sells and distributes, installs, repairs, or maintains a product, or is otherwise involved in placing it in the stream of commerce (OCGA 51-1-11.1(a)).

Does a building code violation make the owner liable?
Not automatically. In American Multi-Cinema, Inc. v. Gillis, No. A24A0537 (Ga. Ct. App. June 27, 2024), the Court of Appeals treated a missing stair rail as an open and obvious static condition and explained that negligence per se does not by itself establish liability.

Can the owner blame a manufacturer that is not in the lawsuit?
Yes, if the procedure is followed. Someone never named as a defendant can still be given a share of fault, and that share counts if the plaintiff settled with the nonparty or a defendant gave notice at least 120 days before trial (OCGA 51-12-33(c), (d)(1)).

  • OCGA 51-3-1; Robinson v. Kroger Co., 268 Ga. 735 (1997)
  • Meadows v. Dollar General Store, 371 Ga. App. 695 (2024); Johnson v. LT Energy, LLC, No. A23A0240 (Ga. Ct. App. June 27, 2023); American Multi-Cinema, Inc. v. Gillis, No. A24A0537 (Ga. Ct. App. June 27, 2024)
  • OCGA 51-1-11(b), (c); OCGA 51-1-11.1(a), (b), (c); Banks v. ICI Americas, Inc., 264 Ga. 732 (1994)
  • OCGA 51-12-33(b), (c), (d)(1)

Disclaimer

This article provides general information about revolving door injury claims under Georgia law. It is not legal advice and does not create an attorney-client relationship. Who is liable depends on who owned, maintained, and made the door, the date of first sale, and the specific facts. A person injured by a revolving door should consult a licensed Georgia attorney promptly about the particular situation.

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