Henry v. Cullum Companies, Inc.
Dovie Irene Henry appealed a summary judgment granted in favor of Cullum Companies, Inc. (Tom Thumb) in a slip-and-fall negligence case. Henry initially sought recovery under the Texas Deceptive Trade Practices-Consumer Protection Act (DTPA), alleging misrepresentations about the safety of the store's floors. The trial court granted a partial summary judgment, ruling that premises liability cases were not within the purview of the DTPA. Henry subsequently removed the DTPA claims from her pleadings. The appellate court affirmed the summary judgment, distinguishing between services as the primary objective of a bargain and incidental services like the use of store floors, concluding that the latter do not fall under the DTPA's definition of services "furnished in connection with the sale of goods." Thus, Henry was not considered a "consumer" under the DTPA for her injury related to the store's floors.