Rebecca Montgomery, a passenger on a Washington Metro train, sued the Washington Metropolitan Area Transit Authority (WMATA) after she fell and suffered a broken hip. The incident occurred when the train, which had come to a full stop at Farragut North Station, suddenly lurched forward without warning as Montgomery attempted to change seats. Montgomery alleged that WMATA was negligent for failing to warn passengers before making this berthing adjustment. After discovery, WMATA moved for summary judgment, arguing that Montgomery had no evidence to prove the applicable standard of care. The district court granted the motion, ruling that expert testimony was required to establish what a train operator should do in this situation. Montgomery appealed, arguing that the standard of care was within the common knowledge of jurors and that WMATA's internal operating procedures should suffice to prove negligence.
The court applied District of Columbia substantive law, which requires a plaintiff to adduce expert testimony to establish the standard of care if the duty is beyond the ken of the average layperson. The court distinguished this case from previous transit negligence cases involving buses, where jurors' experience driving cars allowed them to understand the standard of care without experts. Here, the court reasoned that while jurors may have experience as train passengers, they lack the specialized knowledge to determine what is expected of a train operator regarding berthing adjustments. The court noted that without an expert, jurors would be speculating on how often such adjustments cause jerking motions and whether a warning is required. The court also addressed Montgomery's argument that WMATA's internal operating procedures should define the standard of care. Citing established precedent, the court held that internal manuals cannot, on their own, establish the national standard of care. The court explained that allowing internal procedures to set the standard would create a perverse incentive for transit authorities to write minimal duties into their manuals to limit liability. The court found that the district court correctly rejected the use of internal procedures as a substitute for expert testimony.
The decision reinforces the requirement for plaintiffs in transit negligence cases involving specialized operational duties to secure expert testimony. It clarifies that internal company policies are not dispositive evidence of the legal standard of care. The ruling leaves the district court's summary judgment in favor of WMATA intact, meaning Montgomery's claim is dismissed. The case does not resolve whether a warning is required in all circumstances, but rather establishes that a jury cannot decide that question without expert guidance.
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