eNotes: Liability – October 2024 – Washington, DC

SIGNIFICANT CASE SUMMARIES

Washington, DC Case Summary

Woods v. WMATA
United States District Court for the District of Columbia
Nos. 18-CV-1299 & 18-CV-1386

Decided: July 18, 2024

Res ipsa loquitur may be invoked only where a layman can infer negligence as a matter of common knowledge, or where expert testimony is presented, that such accidents do not occur in the absence of negligence.

Background

Plaintiff Denise McKenney entered the Metrorail system at Foggy Bottom Station and boarded Metro railcar number 6090, heading in the direction of Largo Station. She took a seat at the rear of the car, on a bench-style arrangement without armrests or handles. At the subsequent stop, Smithsonian Station, Plaintiff Kamilah Woods also boarded railcar 6090 and sat beside Ms. McKenney in the same seat. As the train departed and continued towards Benning Road Station, the seat unexpectedly detached from the railcar wall, causing both Plaintiffs to tumble to the floor along with the seat. On January 20, 2018, Plaintiffs filed suit, alleging personal injuries sustained when their seat in a Metro railcar suddenly collapsed.

Following discovery, WMATA moved for summary judgment, arguing that Plaintiffs lacked expert testimony essential to establishing a prima facie case of negligent maintenance and demonstrating WMATA’s prior notice of the seat’s malfunction or defect. The Trial Court granted WMATA’s Motion for summary judgment, ruling that Plaintiffs’ negligence claim failed due to insufficient evidence demonstrating WMATA’s actual or constructive notice of the defective seat condition. Additionally, the Court rejected Plaintiffs’ assertion that expert testimony was unnecessary to establish the standard of care for maintaining Metro railcar seats. Finally, the Trial Court declined to apply the doctrine of res ipsa loquitur, concluding it was inapplicable to the facts of the case. Plaintiffs appealed.

Holding

The United States District Court for the District of Columbia determined that expert testimony was required for Plaintiffs to prove their case. The Court found that while a reasonable juror in the District of Columbia may have sat in a Metro railcar seat and inferred that maintenance is necessary for a visibly defective seat, there is no evidence to suggest that was the case here, as both Plaintiffs occupied a bench seat without visible defects. The Court thus found that since doctrine of res ipsa loquitur is not a strict liability principle, but rather an alternative method of establishing negligence, due to the absence of expert testimony and given the lack of common knowledge regarding the relationship between adequate inspection and maintenance schedules and the seat’s collapse, a jury would have been forced to engage in speculation rather than weighing probabilities based on evidence.

Questions about this case can be directed to Nicholas Schaufelberger at (202) 945-9502 or nschaufelberger@tthlaw.com.