Key similarities in the Brown case and Mrs. Smith's case is that the obstruction was placed there in the store and insinuates that someone in the store was aware of it. In Mabel Smith's case, the employee was restocking the fruit from a crate placed in the middle of the aisle. In the Brown case, the display was placed dangerously at the end of an aisle. The court awarded Brown damages on the grounds that the defendant was negligent in placing the display where customers walked. Negligence can also be championed in the Smith case because an employee knowingly placed an item in the way of where customers walked