Joseph A. Loiga, V. King County

CourtCourt of Appeals of Washington
DecidedNovember 27, 2023
Docket85109-8
StatusUnpublished

This text of Joseph A. Loiga, V. King County (Joseph A. Loiga, V. King County) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Joseph A. Loiga, V. King County, (Wash. Ct. App. 2023).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

JOSEPH A. LOIGA, an individual, No. 85109-8-I Appellant, DIVISION ONE v. UNPUBLISHED OPINION KING COUNTY, a governmental entity by and through KING COUNTY METRO and KING COUNTY DEPARTMENT OF TRANSPORTATION, governmental agencies; and ROXANNE DONALDSON, an individual,

Respondents.

CHUNG, J. — While riding a King County Metro bus, Joseph Loiga fell out

of his seat and hit his head on a metal partition behind the driver’s seat. Loiga

sued King County and the bus driver for negligent operation. Applying the higher

standard of care owed by a common carrier, the trial court dismissed Loiga’s

claims on summary judgment. Because Loiga failed to provide evidence raising a

question of material fact on the issue of breach of the common carrier’s duty, we

affirm.

FACTS

On June 23, 2018, Joseph Loiga suffered a fall while riding King County No. 85109-8-I/2

Metro bus route 166. 1 He was sitting behind the bus driver, in one of the three

adjoined seats parallel to the windows and facing the aisle. As the bus traveled

down 104th Avenue SE, the car in front of the bus was making a right turn, but

slammed on the brakes for a pedestrian crossing the street. Bus operator

Roxanne Donaldson applied the brakes and the bus came to a stop. Loiga fell off

his seat into the aisle and toward the front of the bus where he hit the top of his

head on the metal partition behind the driver’s seat.

After the fall, Loiga initially told Donaldson that he was fine but then

requested medical assistance. The fire department dispatched an aid vehicle.

EMTs2 evaluated Loiga and reported that he “denied an [pain] on palp[ation] of

his neck but a little bit of [pain] on the back of his head with no obvious

deformities.” EMTs placed Loiga in a cervical collar as a precaution. Loiga was

eventually transferred by ambulance to Valley Medical Center. 3

Loiga sued King County and Donaldson for negligent operation. 4 King

County moved for summary judgment, arguing Loiga had failed to produce

evidence of breach of any duty owed to him. The trial court granted summary

judgment and dismissed the claims.

1 We note that Loiga fails to provide citations to the record as required under RAP

10.3(1)(5). 2 Emergency Medical Technicians. 3 In his opening brief, Loiga claims he continued to experience pain, and progressive

weakness, tingling, and numbness is his extremities and was diagnosed with “subacute C5-C6 cervical stenosis with cord flattening and signal change.” However, the record contains no medical evidence after the ambulance transfer to Valley Medical Center. 4 Loiga did not designate the complaint and the complaint is not in the record for review.

This omission violates RAP 9.6(b)(1)(C), which requires, at a minimum, that the designated clerk’s papers include the complaint. Information about the claim is taken from King County’s request for summary judgment.

2 No. 85109-8-I/3

Loiga appeals.

DISCUSSION

We review orders on summary judgment de novo. Kim v. Lakeside Adult

Fam. Home, 185 Wn.2d 532, 547, 374 P.3d 121 (2016). Summary judgment is

appropriate when there is no genuine issue of material fact and the moving party

is entitled to judgment as a matter of law. Folsom v. Burger King, 135 Wn.2d 658,

663, 958 P.2d 301 (1998) (citing CR 56(c)). We consider the evidence and

reasonable inferences in the light most favorable to the nonmoving party. Kim,

185 Wn.2d at 547.

The moving party has the initial burden of showing the absence of an

issue of material fact. In re Est. of Black, 153 Wn.2d 152, 160-61, 102 P.3d 796

(2004). If the moving party meets this burden, the nonmoving party must set forth

specific facts to show a genuine issue for trial. Id. The facts must rebut the

moving party’s contentions and demonstrate the existence of a genuine issue of

material fact. Citibank South Dakota N.A. v. Ryan, 160 Wn. App. 286, 289, 247

P.3d 778 (2011).

Loiga contends the trial court erred by granting summary judgment on his

negligence claim against King County. To prove negligence, a plaintiff must show

(1) the existence of a duty, (2) breach of that duty, (3) resulting injury, and

(4) proximate cause. Ranger Ins. Co. v. Pierce County, 164 Wn.2d 545, 552,

192 P.3d 886 (2008). Generally, whether there has been negligence “is a jury

question, unless the facts are such that all reasonable persons must draw the

same conclusion from them, in which event the question is one of law for the

3 No. 85109-8-I/4

courts.” Hough v. Ballard, 108 Wn. App. 272, 279, 31 P.3d 6 (2001). The

existence of a duty is a question of law. Degel v. Majestic Mobile Manor, Inc.,

129 Wn.2d 43, 48, 914 P.2d 728 (1996). Breach of duty, however, is ordinarily a

factual question, and “if there is any evidence tending to show that the carrier

failed to comply with the required standard of care, then the question of

negligence must be left to the jury.” Walker v. King County Metro, 126 Wn. App.

904, 908, 109 P.3d 836 (2005).

Here, both parties agree that King County Metro bus is a common carrier.

“As a common carrier of passengers, a bus system owes the highest degree of

care toward its passengers commensurate with the practical operation of its

services at the time and place in question.” Price v. Kitsap Transit, 125 Wn.2d

456, 465, 886 P.2d 556 (1994). However, a common carrier’s duty of care is not

one of strict liability, nor is a common carrier the insurer of its passengers’ safety.

Walker, 126 Wn. App. at 908. “[N]egligence should not be presumed or inferred

from the mere happening of an accident.” Id. Specifically, a common carrier is not

liable for injuries received from “ordinary jolts and jerks necessarily incident to the

mode of transportation,” unless there is evidence from which operator negligence

can be reasonably be inferred. Id.

In support of its motion for summary judgment, King County argues that

Loiga has not set forth any facts that provide for an inference of bus operator

negligence, and therefore, fails to meet his burden of demonstrating breach. In

her deposition, Donaldson, who had approximately 30 years of experience as a

bus driver, described her response to the car stopping quickly in front of her:

4 No. 85109-8-I/5

So I put my brakes on. Now, that wasn’t a slam of the brakes because I know what a hard brake is. I know what a medium, a soft brake. That was not a hard brake. That wasn’t a hard brake. That was just, you know, stopping . . . between a soft and a medium.

Internal surveillance video from the bus supports Donaldson’s report. When the

bus stopped, the other people on the bus show little movement and no reactions

of surprise or concern. Loiga, who was sitting on the edge of his seat facing the

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Related

Degel v. Majestic Mobile Manor, Inc.
914 P.2d 728 (Washington Supreme Court, 1996)
Price v. Kitsap Transit
886 P.2d 556 (Washington Supreme Court, 1994)
Folsom v. Burger King
958 P.2d 301 (Washington Supreme Court, 1998)
Citibank (South Dakota), NA v. Ryan
247 P.3d 778 (Court of Appeals of Washington, 2011)
Johnson v. Recreational Equipment, Inc.
247 P.3d 18 (Court of Appeals of Washington, 2011)
Hough v. Ballard
31 P.3d 6 (Court of Appeals of Washington, 2001)
Ranger Ins. Co. v. Pierce County
192 P.3d 886 (Washington Supreme Court, 2008)
In Re Estate of Black
102 P.3d 796 (Washington Supreme Court, 2004)
Degel v. Majestic Mobile Manor, Inc.
129 Wash. 2d 43 (Washington Supreme Court, 1996)
Folsom v. Burger King
135 Wash. 2d 658 (Washington Supreme Court, 1998)
Carlton v. Black
153 Wash. 2d 152 (Washington Supreme Court, 2004)
Ranger Insurance v. Pierce County
164 Wash. 2d 545 (Washington Supreme Court, 2008)
Kim v. Lakeside Adult Family Home
374 P.3d 121 (Washington Supreme Court, 2016)
Hough v. Ballard
108 Wash. App. 272 (Court of Appeals of Washington, 2001)
Walker v. King County Metro
109 P.3d 836 (Court of Appeals of Washington, 2005)
Johnson v. Recreational Equipment, Inc.
159 Wash. App. 939 (Court of Appeals of Washington, 2011)
Smith v. Fourre
858 P.2d 276 (Court of Appeals of Washington, 1993)

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