Cervantes v. Los Angeles County Metro. Trans. Auth. CA2/5

CourtCalifornia Court of Appeal
DecidedNovember 25, 2024
DocketB322192
StatusUnpublished

This text of Cervantes v. Los Angeles County Metro. Trans. Auth. CA2/5 (Cervantes v. Los Angeles County Metro. Trans. Auth. CA2/5) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cervantes v. Los Angeles County Metro. Trans. Auth. CA2/5, (Cal. Ct. App. 2024).

Opinion

Filed 11/25/24 Cervantes v. Los Angeles County Metro. Trans. Auth. CA2/5 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT

DIVISION FIVE

MARIA CERVANTES, B322192

Plaintiff and Appellant, (Los Angeles County Super. Ct. No. v. BC693846)

LOS ANGELES COUNTY METROPOLITAN TRANSPORTATION AUTHORITY,

Defendant and Respondent.

APPEAL from a judgment of the Superior Court of Los Angeles County, Cary H. Nishimoto, Judge. Affirmed. Arbogast Law and David M. Arbogast; Law Offices of Steven Ibarra and Steven Ibarra; The Arkin Law Firm and Sharon J. Arkin for Plaintiff and Appellant. Ivie McNeill Wyatt Purcell & Diggs and W. Keith Wyatt; Greines, Martin, Stein & Richland, Edward L. Xanders, and Alex Chemerinsky for Defendant and Respondent. Plaintiff and appellant Maria Cervantes (Cervantes) sued defendant and respondent Los Angeles County Metropolitan Transportation Authority (MTA) after she fell and sustained injuries aboard an MTA bus. The case proceeded to trial, and the jury returned a verdict for MTA—finding the agency had not been negligent. In this appeal from the resulting judgment, we consider, in the main, whether the trial court erred in instructing the jury on general negligence and dangerous condition of public property and in excluding testimony of Cervantes’s proposed safety expert and evidence of the results of an evaluation by MTA’s Accident Review Board (ARB).

I. BACKGROUND A. The Accident On June 8, 2017, Cervantes boarded an MTA bus and walked toward an open seat. Before she got there, the bus driver, Darryl Bowman (Bowman), accelerated away from the bus stop. Cervantes fell and was injured. The incident was captured on video. Cervantes filed suit against MTA alleging its employee Bowman had acted negligently and its negligence caused her injuries. MTA answered the complaint with a general denial and asserted a series of affirmative defenses, including an assertion that Cervantes’s own negligence caused or contributed to her injury.

B. Motions in Limine 1. Motion in limine to exclude ARB evidence Prior to trial, MTA filed a motion in limine to exclude evidence of post-accident investigations and evaluations

2 conducted by MTA. Though the appellate record does not reveal all the details of the post-accident investigation and evaluation process, it appears MTA convened a first-level ARB comprised of three MTA supervisory personnel who reviewed the accident and determined whether it was avoidable or not. Two of the three members of the first-level ARB, Shakana Turner (Turner) and Christopher Doan (Doan), concluded the accident was avoidable and each completed a written report that cited the rules and standard operating procedures (SOPs) they believed Bowman violated.1 Doan and Turner both concluded Bowman violated MTA rule 3.20 (regarding mirror use) and SOP 3.152 (addressing “Methods for Avoiding . . . Onboard Falls”), but Turner additionally believed Bowman also violated other rules and SOPs. MTA’s motion in limine argued evidence of Turner and Doan’s conclusions should be excluded under Evidence Code section 352 because it would risk confusing the issues at trial. MTA maintained the purpose of ARBs is to promote the safe operation of public transit, not to assess legal liability for negligence. In addition, MTA argued the ARB process was a subsequent remedial measure that should be excluded under Evidence Code section 1151.2

1 The record suggests the third member of the first-level ARB, Patrick Corral, found the accident was unavoidable. 2 The statute provides: “When, after the occurrence of an event, remedial or precautionary measures are taken, which, if taken previously, would have tended to make the event less likely to occur, evidence of such subsequent measures is inadmissible to prove negligence or culpable conduct in connection with the event.”

3 Cervantes opposed the motion in limine and contended evidence of Turner and Doan’s conclusions should not be excluded under either Evidence Code provision. Cervantes argued, in connection with Evidence Code section 1151, that no subsequent remedial measures had been adopted. Citing Dillenbeck v. City of Los Angeles (1968) 69 Cal.2d 472, Cervantes also argued internal determinations of compliance with internal MTA policies and procedures were relevant because the policies and procedures themselves were relevant to determinations of liability. In Cervantes’s view, the jury would understand that evidence of the ARB’s determination was introduced to assist the jury in making its determination, not to supplant that determination. At the hearing on the motion in limine, the court stated the issue was whether the bus driver caused the fall. The court concluded the fact that Bowman was subjected to discipline spoke for itself, and the ARB’s report and testimony related to that report was unnecessary. The court stated that if Bowman denied having been disciplined, Cervantes could then bring in testimony from Doan or Turner—but could not do so otherwise.3 The court’s subsequently issued written ruling described the motion in limine as having been “conditionally granted.” The court found Bowman’s discipline was relevant to the issue of negligence. That, however, made Turner and Doan’s depositions

3 During the hearing, the court also remarked the issue in the case was whether there was negligence in the operation of the bus and mused there was nothing that constituted a dangerous condition of public property. The trial court also stated it did not intend to instruct the jury on dangerous condition of property principles of liability.

4 “irrelevant and unnecessary unless [Bowman] claims he was not disciplined.” The court found there was no subsequent remedial conduct because the evidence went to a finding of fault, not curative changes. The court also identified testimony that might be admitted depending on how Bowman testified, and other testimony that would be relevant regardless: “[T]estimony of Turner and Doan may become relevant to the limited extent that Turner and Doan each had different criticisms of Bowman’s driving regarding Rule violations. Mr. Doan’s deposition testimony regarding when it is safe to accelerate from the bus stop is admissible as relevant to the issue of negligence, especially in combination with the video of the accident. Beyond this evidence, the written findings of [the ARB] are irrelevant and unnecessary to the jury’s duty to determine if plaintiff has met its burden of proof.”

2. Motion in limine to exclude plaintiff’s expert testimony In addition to its ARB motion in limine, MTA filed a motion in limine to preclude expert testimony regarding liability issues. The motion argued the facts of the accident were clearly depicted on video, expert opinions on liability would be based on the same information available to the jury, and the experts could not add any information that was beyond the jury’s common experience. MTA accordingly sought to exclude testimony from Cervantes’s proposed safety expert, Brad Avrit (Avrit), and her biomechanical engineering expert, Bradley Rutledge (Rutledge). Because the trial court allowed Rutledge to testify, we describe the motion only insofar as it related to Avrit.

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Cervantes v. Los Angeles County Metro. Trans. Auth. CA2/5, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cervantes-v-los-angeles-county-metro-trans-auth-ca25-calctapp-2024.