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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA 

Case No. 1:20-cv-23308

CHRISTOPHER SELFRIDGE, 

Plaintiff,

v.

CARNIVAL CORPORATION, 

Defendant. 

__________________________________/ 

COMPLAINT FOR DAMAGES 

AND DEMAND FOR TRIAL BY JURY

Plaintiff, CHRISTOPHER SELFRIDGE (“Plaintiff”), through undersigned counsel, sues 

Defendant, CARNIVAL CORPORATION (“Defendant”), and demands trial by jury, stating as 

follows:

PARTIES AND JURISDICTION

1. Plaintiff seeks damages in excess of $75,000.00, exclusive of interest, costs and

attorney’s fees.

2. This Court has admiralty and maritime jurisdiction pursuant to 28 U.S.C.§ 1333 as

the causes of action asserted are maritime torts. 

3. This Court has diversity jurisdiction pursuant to 28 U.S.C. § 1332, as the matter in

controversy exceeds the sum or value of $75,000.00, exclusive of interest and costs, and is between 

citizens of different States and/or citizens of a State and citizens or subjects of a foreign state. 

4. Suit is filed in federal court because of the federal forum selection clause in the

passenger contract ticket issued by the Defendant.

5. Plaintiff is sui juris and is a resident and citizen of the state of Arizona.

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6. Defendant is a foreign corporation who is authorized to conduct and who does 

conduct business in the State of Florida, who at all times material hereto was and is doing business 

in Miami-Dade County, Florida, and who maintains its corporate headquarters and principal place 

of business in Miami-Dade County Florida.

7. Defendant is a dual citizen of the State of Florida and the nation of Panama.

8. Defendant, at all times material hereto, personally or through an agent, in MiamiDade County Florida, in the Southern District of Florida:

a. Operated, conducted, engaged in or carried on a business venture in this

state and/or county; and/or

b. Had an office or agency in this state and/or county; and/or

c. Engaged in substantial activity within this state; and/or

d. Committed one or more of the acts stated in Florida Statutes, Sections 

48.081, 48.181 or 48.193.

9. All conditions precedent for filing and maintaining this action have been fulfilled,

have been waived, or do not apply.

FACTUAL ALLEGATIONS

10. At all times material hereto, Defendant, CARNIVAL, owned, operated, managed, 

maintained, and/or controlled the vessel, the Carnival Imagination.

11. On or about October 12, 2019 Plaintiff was a lawfully fare paying passenger aboard 

Defendant’s cruise ship vessel, the Carnival Imagination.

12. As Plaintiff was entering the library on deck 8 of the Carnival Imagination in a normal 

and proper manner, Plaintiff was opening the door to the library, when the glass door, which 

unbeknownst to Plaintiff was unreasonably heavy, suddenly, and without warning, abruptly

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slammed on him at an unusually fast speed, causing Plaintiff to be propelled forward and for him 

to trip on an elevated edge of a rug in the area, and to fall on his left shoulder. The defective and/or 

malfunctioning condition of this door and rug were conditions that were known or should have 

been known by Defendant because Defendant’s crew members regularly used the door and 

traversed the library area and the rug and were familiar with the dangerous and defective conditions 

thereof, the lengthy period of time the condition existed, prior incidents involving, among other 

things, other incidents where the same or similar doors closed on people, and/or complaints 

regarding the same or similar doors and rugs, and/or other similar circumstances, and/or other 

reasons. As a result of the incident, Plaintiff suffered traumatic injuries that included, but is not 

limited to, a severely torn rotator cuff, requiring surgery. (The subject “doors” shall include, but not 

be limited to, the doors and all material pertaining thereto, including the handles, door closers, returns, 

joints, observation material, maintenance material, any other applied, adhesive, and/or other material, 

and operational material, including, but not limited to, sensors and/or timing material) (the subject 

“rug” shall include, but not be limited to, the rug and all material pertaining thereto, including any 

applied, adhesive, and/or other material).

COUNT I

NEGLIGENT HIRING AND RETENTION

13. Plaintiff hereby adopts and re-alleges each and every allegation in paragraphs 10 

through 12 as if set forthherein.

14. The Defendant owed Plaintiff the duty to exercise reasonable care under the 

circumstances for the safety of its passengers.

15. Such duty includes, but is not limited to, the duty to provide its passengers reasonable 

care to inspect for, resolve, and/or repair dangerous, hazardous, and/or risk- creating conditions that 

passengers, including the Plaintiff, will likely encounter.

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16. Such duty includes, but is not limited to, the duty to maintain its ship in a reasonably safe 

condition for the use and enjoyment of its passengers

17. Such duty includes, but is not limited to, the duty to warn passengers of hazards which 

passengers may reasonably be expected to encounter.

18. At all times material, Defendant, through its officers, managers, recruiters, vessel, 

and/or other agents, employees, staff, crew, and/or representatives, who were acting in the course 

and scope of their employment and/or agency with Carnival, breached the duty of reasonable care 

owed to the Plaintiff and was negligent through negligently vetting, selecting, hiring, and/or 

retaining its crewmembers responsible for inspecting, cleaning, and/or maintaining the subject 

doors, rug, area, and the vicinity, warning passengers of the dangerous conditions, and/or 

otherwise making sure the area where Plaintiff fell was safe, and Defendant knew or should have 

known these crewmembers were dangerous, incompetent, unqualified, and/or liable to do harm.

19. It was foreseeable to Defendant that passengers like Plaintiff would suffer incidents

if the subject doors were unreasonably heavy, closed abruptly, and closed at an unusually fast 

speed, and that the subject rug was at risk of passengers’ feet getting caught in it, and/or that the 

subject doors, rug, area, and the vicinity were otherwise risk creating and/or dangerous.

20. It was therefore foreseeable that the area would require proper inspection, cleaning, 

maintenance, warning passengers of risk creating and/or dangerous, and/or other efforts to make 

sure the area where Plaintiff fell was safe.

21. At all times material, the Defendant owed a duty to use reasonable care in hiring 

and/or retaining all crewmembers.

22. When Defendant elected to hire its crewmembers, it had a duty to vet, select, and/or 

hire crewmembers who were adequately qualified, trained, and experienced to work aboard ships 

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and to adequately conduct inspections, cleanings, maintenance, warning passengers of risk 

creating and/or dangerous, and/or to make other efforts to make sure the area where Plaintiff fell 

was safe.

23. Defendant negligently knew or should have known that the ship’s crewmembers were 

dangerous and incompetent and liable to do harm to its passengers.

24. Defendant failed to conduct a reasonable investigation regarding the competence of the 

ship’s crewmembers responsible for inspecting, cleaning, and/or maintaining the subject doors, rug,

area, and the vicinity, warning passengers of risk creating and/or dangerous, and/or otherwise 

making sure the area where Plaintiff fell was safe, including failing to adequately evaluate its 

crewmembers’ performance during their tenure with it, and including, but not limited to, by failing to 

properly review and/or analyze their success record in how often they were able to adequately inspect, 

clean, and/or maintain the subject doors, rug, area, and the vicinity, warn passengers of risk 

creating and/or dangerous conditions, and/or otherwise make sure the area where Plaintiff fell was 

safe, and failing to adequately discipline and/or terminate their employment when their track record 

was inadequate and/or improper.

25. Both prior to and during the course of employment of said crewmembers, Defendant 

became aware or should have become aware of problems with said crewmembers that indicated their 

unfitness and/or predisposition to failing to adequately inspect, clean, and/or maintain the subject 

doors, rug, area, and the vicinity, warn passengers of the risk creating and/or dangerous conditions, 

and/or otherwise make sure the area where Plaintiff fell was safe, for reasons that include, but is not 

limited to, that Defendant received, made, and/or was otherwise aware of complaints of the same or 

similar errors, as well as previous failures to adequately perform inspections, cleanings, maintenance, 

warning passengers of the risk creating and/or dangerous conditions, and/or failures to perform 

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other activities to help make sure the area where Plaintiff fell was safe. Defendant received 

complaints of these crewmembers’ incompetence, and/or was otherwise aware that they did not have 

adequate training, qualifications, or experience for performing inspections, cleanings, maintenance, 

warning passengers of the risk creating and/or dangerous conditions, and/or failures to perform 

other activities to help make sure the area where Plaintiff fell was safe, which indicated their 

unfitness and/or predisposition to committing errors, but Defendant failed to take further action such 

as investigating, discharging, or reassignment.

26. Defendant owed Plaintiff and its passengers a duty of care, when hiring crewmembersto 

hire and retain only competent crewmembers.

27. Defendant breached its duty of care to Plaintiff by hiring and retaining incompetent 

crewmembers.

28. As a proximate result, Defendant’s crewmembers’ failured to perform adequate 

inspections, cleanings, maintenance, warning passengers of the risk creating and/or dangerous 

conditions, and/or other activities to help make sure the area where Plaintiff fell was safe, and 

Plaintiff’s incident occurred, and Plaintiff suffered severe injuries as a result.

29. Defendant’s negligence proximately caused Plaintiff great bodily harm in that, but for 

Defendant’s negligence, Plaintiff’s injuries would not have occurred and/or would have been 

substantially lessened.

30. As a result of the Defendant’s negligence, Plaintiff has suffered severe bodily 

injury resulting in pain and suffering, disability, disfigurement, mental anguish, loss of capacity 

for the enjoyment of life, expense of hospitalization, medical and nursing care and treatment, 

lost wages, and loss of ability to earn money. 

31. The losses are either permanent or continuing in nature. 

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32. Plaintiff has suffered these losses in the past and will continue to suffer such loses 

in the future.

WHEREFORE, Plaintiff, CHRISTOPHER SELFRIDGE, demands Judgment against 

Defendant, CARNIVAL CORPORATION, for damages suffered and costs incurred, as well as for 

damages and costs that Plaintiff will suffer and incur in the future, as a result of Plaintiff’s bodily 

injury, pain and suffering, disability, disfigurement, scarring, mental anguish, hospitalization, medical 

care and treatment, nursing care and treatment, loss of earnings, loss of ability to earn money, loss of 

important bodily functions, and loss of capacity for the enjoyment of life; for all court costs, pre- and 

post-judgment interest, and for any and all other relief which the Court deems just or appropriate.

COUNT II

NEGLIGENT SUPERVISION AND TRAINING

33. Plaintiff hereby adopts and re-alleges each and every allegation in paragraphs 10 

through 12 as if set forthherein.

34. The Defendant owed Plaintiff the duty to exercise reasonable care under the 

circumstances for the safety of its passengers.

35. Such duty includes, but is not limited to, the duty to provide its passengers reasonable 

care to inspect for, resolve, and/or repair dangerous, hazardous, and/or risk-creating conditions that 

passengers, including the Plaintiff, will likely encounter.

36. Such duty includes, but is not limited to, the duty to maintain its ship in a reasonably safe 

condition for the use and enjoyment of its passengers

37. Such duty includes, but is not limited to, the duty to warn passengers of hazards which 

passengers may reasonably be expected to encounter.

38. At all times material, Defendant, through its officers, managers, recruiters, vessel, 

and/or other agents, employees, staff, crew, and/or representatives, who were acting in the course 

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and scope of their employment and/or agency with Carnival, breached the duty of reasonable care 

owed to the Plaintiff and was negligent through negligently supervising and/or training its 

crewmembers, whom Defendant knew or should have known were dangerous, incompetent, 

unqualified, and/or liable to do harm.

39. It was foreseeable to Defendant that passengers like Plaintiff would suffer incidents

if the subject doors were unreasonably heavy, closed abruptly, and closed at an unusually fast 

speed, and that the subject rug was at risk of passengers’ feet getting caught in it, and/or that the 

subject doors, rug, area, and the vicinity were otherwise risk creating and/or dangerous.

40. It was therefore foreseeable that the area would require proper inspection, cleaning, 

maintenance, warning passengers of the risk creating and/or dangerous conditions, and/or other 

efforts to make sure the area where Plaintiff fell was safe.

41. At all times material, the Defendant owed a duty to use reasonable care in supervising 

and/or training its crewmembers.

42. Defendant elected to hire crewmembers to inspect, clean, and/or maintain the subject 

doors, rug, area, and the vicinity, warn passengers of the risk creating and/or dangerous conditions, 

and/or make other efforts to make sure the area where Plaintiff fell was safe, and it owed a duty to 

Plaintiff and its passengers to properly supervise and train these crewmembers to adequately 

perform these inspections, cleanings, maintenance, warning passengers of the risk creating and/or 

dangerous conditions, and/or other efforts to make sure the area where Plaintiff fell was safe.

43. Defendant negligently knew or should have known that these crewmembers were 

dangerous and incompetent and liable to do harm to its passengers.

44. Defendant failed to conduct a reasonable investigation regarding the competence of these 

crewmembers, including failing to adequately evaluate its crewmembers’ performance during their 

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tenure with it, including, but not limited to, by failing to properly review and/or analyze their success 

record in how often they were able to adequately inspect, clean, and/or maintain the subject doors, 

rug, area, and the vicinity, and warn passengers of the risk creating and/or dangerous conditions, 

and/or make other efforts to make sure the area where Plaintiff fell was safe, and failing to 

adequately discipline and/or terminate their employment when their track record was inadequate and/or 

improper.

45. Both prior to and during the course of employment of said crewmembers, Defendant 

became aware or should have become aware of problems with said crewmembers that indicated their 

unfitness and/or predisposition to failing to adequately inspect, clean, and/or maintain the subject 

doors, rug, area, and the vicinity, warn passengers of the risk creating and/or dangerous conditions, 

and/or otherwise make sure the area where Plaintiff fell was safe, for reasons that include, but is not 

limited to, that Defendant received, made, and/or was otherwise aware of complaints of the same or 

similar errors, as well as previous failures to adequately perform inspections, cleanings, maintenance, 

warning passengers of the risk creating and/or dangerous conditions, and/or failures to perform 

other activities to help make sure the area where Plaintiff fell was safe. Defendant received 

complaints of these crewmembers’ incompetence, and/or was otherwise aware that they did not have 

adequate training, qualifications, or experience for performing inspections, cleanings, maintenance, 

warning passengers of the risk creating and/or dangerous conditions, and/or failures to perform 

other activities to help make sure the area where Plaintiff fell was safe, which indicated their 

unfitness and/or predisposition to committing errors, but Defendant failed to take further action such 

as investigating, discharging, or reassignment.

46. Defendant breached its duty of care to Plaintiff by failing to provide its crewmembers

with proper supervision and/or training to adequately conduct inspections, cleaning, maintenance, 

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warning passengers of the risk creating and/or dangerous conditions, and/or other efforts to make 

sure the area where Plaintiff fell was safe.

47. As a proximate result, Defendant’s crewmembers’ failured to perform adequate 

inspections, cleanings, maintenance, warning passengers of the risk creating and/or dangerous 

conditions, and/or other activities to help make sure the area where Plaintiff fell was safe, and 

Plaintiff’s incident occurred, and Plaintiff suffered severe injuries as a result.

48. Defendant’s negligence proximately caused Plaintiff great bodily harm in that, but for 

Defendant’s negligence, Plaintiff’s injuries would not have occurred and/or would have been 

substantially lessened.

49. As a result of the Defendant’s negligence, Plaintiff has suffered severe bodily injury 

resulting in pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the 

enjoyment of life, expense of hospitalization, medical and nursing care and treatment, lost wages, 

and loss of ability to earn money. 

50. The losses are either permanent or continuing in nature.

51. Plaintiff has suffered these losses in the past and will continue to suffer such loses 

in the future.

WHEREFORE, Plaintiff, CHRISTOPHER SELFRIDGE, demands Judgment against 

Defendant, CARNIVAL CORPORATION, for damages suffered and costs incurred, as well as for 

damages and costs that Plaintiff will suffer and incur in the future, as a result of Plaintiff’s bodily 

injury, pain and suffering, disability, disfigurement, scarring, mental anguish, hospitalization, 

medical care and treatment, nursing care and treatment, loss of earnings, loss of ability to earn 

money, loss of important bodily functions, and loss of capacity for the enjoyment of life; for all court 

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costs, pre- and post-judgment interest, and for any and all other relief which the Court deems just or 

appropriate.

COUNT III

NEGLIGENT FAILURE TO WARN OF DANGEROUS CONDITIONS

52. Plaintiff hereby adopts and re-alleges each and every allegation in paragraphs 10 

through 12 as if set forth herein.

53. At all times relevant, Defendant owed a duty to exercise reasonable care under the 

circumstances for the safety of its passengers, including Plaintiff.

54. Such duty includes, but is not limited to, the duty that Defendant owes to warn 

passengers of any dangers that it knew or should have known of that were not open and obvious 

to Plaintiff.

55. Such duty also includes, but is not limited to, the duty to warn passengers of hazards 

which passengers may reasonably be expected to encounter.

56. At all times material, Defendant, through its vessel, crew, agents, employees, staff 

and/or representatives, who were acting in the course and scope of their employment and/or agency 

with Defendant, breached the duty of reasonable care owed to the Plaintiff and was negligent by 

failing to warn Plaintiff of the dangers posed by the subject doors, rug, area, and the vicinity, of 

which Defendant knew or should have known of.

57. These dangerous conditions were also created by Defendant.

58. Defendant either failed to adequately inspect the area to ensure that there were no 

dangerous conditions that passengers needed to be warned of, or Defendant failed to warn Plaintiff 

despite knowing of the dangers.

59. In addition, Defendant either knew or should have known of these dangerous 

conditions, due to reasons that include, but is not limited to, prior substantially similar incidents, 

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complaints of incidents, complaints of these conditions, the length of time that these conditions 

existed, Defendant’s participation in the instillation and/or design of the subject doors, rug, area, 

and the vicinity, Defendant’s acceptance of the ship with these design defects, because these 

conditions violated relevant safety standards/recommendations/other guidelines, and/or for other 

reasons that will be revealed during discovery.

60. Furthermore, the subject doors, rug, area, and the vicinity were also on a cruise ship 

in the water subject to numerous maritime conditions such as the ship’s movement, additional wear 

and tear due to maritime conditions not necessarily present on land, waves, and other conditions 

unique to maritime travel, and as such were “clearly linked to nautical adventure.”

61. These dangerous conditions existed for a period of time before the incident. 

62. These conditions were neither open nor obvious to Plaintiff. 

63. Defendant’s breach was the cause in-fact of Plaintiff’s great bodily harm in that, but 

for Defendant’s breach, Plaintiff’s injuries would not have occurred.

64. Defendant’s breach proximately caused Plaintiff great bodily harm in that the incident 

that occurred was a foreseeable result of Defendant’s breach.

65. As a result of Defendant’s negligence, Plaintiff has suffered severe bodily injury 

resulting in pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the 

enjoyment of life, expense of hospitalization, medical and nursing care and treatment, lost wages, 

and loss of future earning capacity.

66. The losses are either permanent or continuing in nature.

67. Plaintiff has suffered these losses in the past and will continue to suffer such loses in 

the future.

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WHEREFORE, Plaintiff, CHRISTOPHER SELFRIDGE, demands Judgment against 

Defendant, CARNIVAL CORPORATION, for damages suffered and costs incurred, as well as for 

damages and costs that Plaintiff will suffer and incur in the future, as a result of Plaintiff’s bodily 

injury, pain and suffering, disability, disfigurement, scarring, mental anguish, hospitalization, 

medical care and treatment, nursing care and treatment, lost wages, loss of ability to earn money 

in the future, loss of important bodily functions, and loss of capacity for the enjoyment of life; for 

all court costs, pre- and post-judgment interest, and for any and all other relief which the Court 

deems just or appropriate.

COUNT IV

NEGLIGENT DESIGN, INSTALLATION, AND/OR APPROVAL OF THE SUBJECT 

DOORS, RUG, AREA, AND THE VICINITY

68. Plaintiff hereby adopts and re-alleges each and every allegation in paragraphs 10 

through 12 as if set forth herein.

69. At all times material hereto, Defendant owed a duty to its passengers, and in particular 

to Plaintiff, not to permit hazards to be in places where they could harm passengers, such as the 

area of the incident, as well as to design and install reasonable safeguards.

70. At all times material hereto, Defendant participated in the design process of the 

subject vessel by generating design specifications for the shipbuilder to follow, and put the vessel 

on which the Plaintiff was injured into the channels of trade, and/or Defendant approved of the 

subject vessel’s design, including the design of the subject doors, rug, area, and the vicinity.

71. At all times material hereto, Defendant manufactured, designed, installed, and/or 

approved of the Carnival Imagination, including providing specifications to the shipbuilder in the 

original build process, and/or during its refurbishments, and as such owed a duty to its passengers, 

and in particular to the Plaintiff, to design, install and/or approve of the subject doors, rug, area, 

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and the vicinity without any defects.

72. At all times material hereto, Defendant through its agents and/or employees who were 

acting in the course and scope of their employment and/or agency with Defendant, designed, 

installed, and/or approved of the subject doors, rug, area, and the vicinity involved in Plaintiff’s 

incident, which was also in violation of the applicable industry standards/recommendations/and/or 

other guidelines.

73. Upon information and belief, Defendant provides design elements of the vessels to 

the ship builder and/or approves of design elements which include the subject doors, rug, area, and 

the vicinity

74. Upon information and belief, Defendant maintains the contractual right to participate, 

review, modify, and/or reject the design plans and drawings of the vessels, including the Carnival 

Imagination, during the new build process.

75. Upon information and belief, Defendant has the right to enter the ship and inspect it 

during construction to ensure that it is being constructed in accordance with the design 

specifications and has a right to insist on changes when safety concerns are identified.

76. Upon information and belief, Defendant has the right to inspect and reject design 

elements before taking possession of the ship.

77. At all times material hereto, Defendant knew or had reason to know the subject doors, 

rug, area, and the vicinity involved in Plaintiff’s incident were unreasonably dangerous.

78. Defendant should have known of these dangerous conditions through inspecting the 

subject doors, rug, area, and the vicinity involved in Plaintiff’s incident, and if it did not know of 

these dangerous conditions, this was because it failed to adequately inspect the subject doors, rug, 

area, and the vicinity involved in Plaintiff’s incident.

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79. In addition, Defendant either knew or should have known of these dangerous 

conditions, due to reasons that include, but is not limited to, prior substantially similar incidents, 

complaints of incidents, complaints of these conditions, the length of time that these conditions 

existed, because these conditions violated relevant safety standards, and/or for other reasons that 

will be revealed during discovery.

80. Furthermore, the subject doors, rug, area, and the vicinity were also on a cruise ship 

in the water subject to numerous maritime conditions such as the ship’s movement, additional wear 

and tear due to maritime conditions not necessarily present on land, waves, and other conditions 

unique to maritime travel, and as such were “clearly linked to nautical adventure.”

81. However, Defendant permitted dangerous deficiencies to be present in the area of the 

incident without correcting these design deficiencies, and did not design and install reasonable 

safeguards.

82. The design flaws that made the subject doors, rug, area, and the vicinity involved in 

Plaintiff’s incident unreasonably dangerous were the direct and proximate cause of Plaintiff’s 

injuries.

83. Defendant is liable for the design flaws of the vessel, including of the subject doors, 

rug, area, and the vicinity involved in Plaintiff’s incident, which it knew or should have known of.

84. Defendant failed to correct and/or remedy the defective conditions despite the fact 

that it knew or should have known their danger.

85. As a result of Defendant’s negligence, Plaintiff has suffered severe bodily injury 

resulting in pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the 

enjoyment of life, expense of hospitalization, medical and nursing care and treatment, lost wages, 

and loss of future earning capacity.

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86. The losses are either permanent or continuing in nature.

87. Plaintiff has suffered these losses in the past and will continue to suffer such loses in 

the future.

WHEREFORE, Plaintiff, CHRISTOPHER SELFRIDGE, demands Judgment against 

Defendant, CARNIVAL CORPORATION, for damages suffered and costs incurred, as well as for 

damages and costs that Plaintiff will suffer and incur in the future, as a result of Plaintiff’s bodily 

injury, pain and suffering, disability, disfigurement, scarring, mental anguish, hospitalization, 

medical care and treatment, nursing care and treatment, lost wages, loss of ability to earn money 

in the future, loss of important bodily functions, and loss of capacity for the enjoyment of life; for 

all court costs, pre- and post-judgment interest, and for any and all other relief which the Court 

deems just or appropriate.

COUNT V

NEGLIGENCE AGAINST DEFENDANT FOR THE ACTS OF ITS CREWMEMBERS 

BASED ON VICARIOUS LIABILITY

88. Plaintiff hereby adopts and re-alleges each and every allegation in paragraphs 10 

through 12 as if set forth herein.

89. Defendant at all relevant times, owed the Plaintiff a non-delegable duty to exercise 

the reasonable care required for the safety of a fare-paying passenger.

90. Alternatively, Defendant owed a duty to exercise reasonable care under the 

circumstances for the safety of its passengers.

91. To the extent Defendant contests its responsibility for the conduct of its crew 

members, including the crew member(s) that failed to adequately inspect, clean, and/or maintain 

the subject doors, rug, area, and the vicinity, warn passengers of the risk creating and/or dangerous 

conditions, and/or do other activities to help make sure the subject doors, rug, area, and the vicinity

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were safe, Plaintiff alleges that these individuals were agents of Defendant, for the following 

reasons:

92. The crewmembers were the employees of Defendant, or were Defendant’s agents, 

apparent agents, and/or servants.

93. The crewmembers were subject to the right of control by Defendant.

94. The crewmembers were acting within the scope of their employment or agency.

95. Defendant acknowledged that the crew and officers would act on Defendant’s behalf, 

and they accepted the undertaking.

96. Defendant is vicariously liable for the acts of its crewmembers.

97. Defendant is vicariously liable for its crew members’ negligent acts of failing to 

inspect, clean, and/or maintain, the subject doors, rug, area, and the vicinity, failing to warn 

passengers of the risk creating and/or dangerous conditions, and/or failing to do other activities to 

help make sure the subject doors, rug, area, and the vicinity were safe.

98. This negligence proximately caused Plaintiff great bodily harm in that, but for this 

negligence, Plaintiff’s injuries would not have occurred.

99. As a result of Defendant’s negligence, Plaintiff has suffered severe bodily injury 

resulting in pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the 

enjoyment of life, expense of hospitalization, medical and nursing care and treatment, lost wages, 

and loss of future earning capacity.

100. The losses are either permanent or continuing in nature.

101. Plaintiff has suffered these losses in the past and will continue to suffer such loses in 

the future.

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WHEREFORE, Plaintiff, CHRISTOPHER SELFRIDGE, demands Judgment against 

Defendant, CARNIVAL CORPORATION, for damages suffered and costs incurred, as well as 

for damages and costs that Plaintiff will suffer and incur in the future, as a result of Plaintiff’s 

bodily injury, pain and suffering, disability, disfigurement, scarring, mental anguish, 

hospitalization, medical care and treatment, nursing care and treatment, lost wages, loss of 

ability to earn money in the future, loss of important bodily functions, and loss of capacity for 

the enjoyment of life; for all court costs, pre- and post-judgment interest, and for any and all 

other relief which the Court deems just or appropriate.

COUNT VI

NEGLIGENT FAILURE TO INSPECT, CLEAN, MAINTAIN, AND/OR OTHERWISE 

REPAIR/REMEDY PREMISES

102. Plaintiff hereby adopts and re-alleges each and every allegation in paragraphs 10 

through 12 as if set forthherein.

103. Defendant owed a duty to exercise reasonable care under the circumstances for the 

safety of its passengers.

104. This duty includes, but is not limited to, the duty to provide its passengers reasonable 

care by inspecting, cleaning, maintaining, and repairing/remedying its ship and all parts thereof, 

so that it is in a reasonably safe condition for the use and enjoyment of its passengers, including, 

but not limited to, by inspecting, cleaning, maintaining, and repairing/remedying the subject doors, 

rug, area, and the vicinity.

105. At all times material, Defendant, through its vessel, crew, agents, employees, staff 

and/or representatives, who were acting in the course and scope of their employment and/or agency 

with Defendant, breached the duty of reasonable care owed to the Plaintiff and were negligent by 

failing to inspect, clean, maintain, and to remedy/repair the subject doors, rug, area, and the vicinity

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involved in Plaintiff’s incident such that the unreasonably risk creating and/or dangerous 

conditions existed, and/or the subject door did not function properly.

106. These risk creating and/or dangerous conditions were caused by design defects and/or

by Defendant’s failure to adequately inspect, clean, maintain, and/or to repair/remedy the subject 

doors, rug, area, and the vicinity involved in Plaintiff’s incident.

107. Defendant’s failure to adequately clean, maintain and/or repair/remedy the subject 

doors, rug, area, and the vicinity involved in Plaintiff’s incident was either due to its failure to 

adequately inspect, them prior to Plaintiff’s incident to ensure that they were in a reasonably safe 

condition, or due to its failure to adequately clean, maintain and/or repair/remedy them despite its 

knowledge of the dangerous conditions, which posed a risk to its passengers.

108. In addition, Defendant either knew or should have known of these dangerous 

conditions, due to reasons that include, but are not limited to, prior substantially similar incidents, 

complaints of incidents, complaints of these conditions, the length of time that these conditions 

existed, Defendant’s participation in the instillation and/or design of the subject doors, rug, area, 

and the vicinity involved in Plaintiff’s incident, Defendant’s acceptance of the ship with these 

design defects, and/or because these conditions violated relevant safety standards.

109. Furthermore, the subject doors, rug, area, and the vicinity were also on a cruise ship 

in the water subject to numerous maritime conditions such as the ship’s movement, additional wear 

and tear due to maritime conditions not necessarily present on land, waves, and other conditions 

unique to maritime travel, and as such were “clearly linked to nautical adventure.”

110. Defendant’s negligence proximately caused Plaintiff great bodily harm in that, but 

for Defendant’s negligence, Plaintiff’s injuries would not have occurred.

111. As a result of Defendant’s negligence, Plaintiff has suffered severe bodily injury 

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resulting in pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the 

enjoyment of life, expense of hospitalization, medical and nursing care and treatment, lost wages, 

and loss of future earning capacity.

112. The losses are either permanent or continuing in nature.

113. Plaintiff has suffered these losses in the past and will continue to suffer such loses in 

the future.

WHEREFORE, Plaintiff, CHRISTOPHER SELFRIDGE, demands Judgment against 

Defendant, CARNIVAL CORPORATION, for damages suffered and costs incurred, as well as for 

damages and costs that Plaintiff will suffer and incur in the future, as a result of Plaintiff’s bodily 

injury, pain and suffering, disability, disfigurement, scarring, mental anguish, hospitalization, 

medical care and treatment, nursing care and treatment, lost wages, loss of ability to earn money 

in the future, loss of important bodily functions, and loss of capacity for the enjoyment of life; for 

all court costs, pre- and post-judgment interest, and for any and all other relief which the Court 

deems just or appropriate.

(Space Intentionally Blank)

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DEMAND FOR JURY TRIAL

Plaintiff, CHRISTOPHER SELFRIDGE, demands trial by jury on all issues so triable.

Dated: August 10, 2020.

Respectfully submitted,

/s/ Matthias M. Hayashi 

Spencer M. Aronfeld, Esq.

Florida Bar No.: 905161

aronfeld@Aronfeld.com 

Abby H. Ivey, Esq.

Florida Bar No.: 1002774

aivey@aronfeld.com

Matthias M. Hayashi

Florida Bar No.: 115973

mhayashi@aronfeld.com

ARONFELD TRIAL LAWYERS

1 Alhambra Plaza, Penthouse

Coral Gables, Florida 33134

P: (305) 441.0440

F: (305) 441.0198

Attorneys for Plaintiff

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