Metropolitan Atlanta Rapid Transit Authority v. Norman Brown

CourtCourt of Appeals of Georgia
DecidedDecember 6, 2022
DocketA22A1470
StatusPublished

This text of Metropolitan Atlanta Rapid Transit Authority v. Norman Brown (Metropolitan Atlanta Rapid Transit Authority v. Norman Brown) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Metropolitan Atlanta Rapid Transit Authority v. Norman Brown, (Ga. Ct. App. 2022).

Opinion

FIRST DIVISION BARNES, P. J., BROWN and HODGES, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules

December 6, 2022

In the Court of Appeals of Georgia A22A1470. METROPOLITAN ATLANTA RAPID TRANSIT AUTHORITY v. BROWN.

BROWN, Judge.

We granted Metropolitan Atlanta Rapid Transit Authority’s (MARTA) request

for an interlocutory appeal to determine whether the trial court erred in denying

MARTA’s motion for summary judgment on Norman Brown’s negligence claim

arising from his fall on a MARTA train as it was departing the Georgia State station.

Brown’s complaint alleged that MARTA negligently failed to provide sufficient time

for him to safely secure himself prior to departure. For the reasons that follow, we

reverse the denial of summary judgment.

To prevail at summary judgment under OCGA § 9-11-56, the moving party must demonstrate that there is no genuine issue of material fact and that the undisputed facts, viewed in the light most favorable to the nonmoving party, warrant judgment as a matter of law. A defendant may do this by showing the court that the documents, affidavits, depositions and other evidence in the record reveal that there is no evidence sufficient to create a genuine jury issue on at least one essential element of plaintiff’s case. A defendant who will not bear the burden of proof at trial need not affirmatively disprove the nonmoving party’s case; instead, the burden on the moving party may be discharged by pointing out by reference to the affidavits, depositions and other documents in the record that there is an absence of evidence to support the nonmoving party’s case.

(Citation and punctuation omitted.) MARTA v. Fife, 220 Ga. App. 298, 298-299 (469

SE2d 420) (1996). Viewing the evidence in favor of Brown, the record shows that on

June 28, 2017, at approximately 5:30 to 6:00 p.m., “in the rush hour,” Brown boarded

a train at the Georgia State station to return home. Brown was using a walker because

he could not “stand that good” and had difficulty walking as a result of gout in his

leg. Brown recalled that a lot of people were getting on the train, that the train was

packed, that he was one of the last people to get on the train, and that he took “one

or two steps” when “all of a sudden the train pulled off fast now, I remember falling.”

Brown remembers hitting the floor but does not remember anything after that because

he hit his head. Brown explained that he “had just got[ten] on the train” and was

“standing there when [the train] pulled off fast, I fell because I couldn’t stand that

2 good. Just like that wheel of the walker just went one way and I went the other way.

That’s the only thing I remember.” He testified that he could not get to a seat because

it happened so fast. He was not holding onto a safety strap because “he wasn’t that

close to it” and had “just barely” come “through the door.” According to Brown, he

had a concussion from the fall and a knee injury, which required surgery. Brown sued

MARTA, asserting claims for negligence and negligence per se under OCGA §§ 46-

9-11 and 46-9-132.2

MARTA’s 30 (b) (6) representative testified that the train operator is

responsible for determining the exact moment a train departs a station: “Once they

pull into a station and passengers either enter the train or exit the train and they safely

close the doors and they have a green signal, they’re okay to proceed.” Once the

doors close, the train operator may depart the station right away, but as the

representative explained, the operator first has to get down from the operator seat he

1 “Carriers as such are bound to exercise ordinary diligence. Common carriers as such are bound to use extraordinary diligence, and in cases of loss the presumption of law is against them, and no excuse avails them unless the loss was occasioned by the act of God or the public enemies of the state.” OCGA § 46-9-1. 2 “A carrier of passengers must exercise extraordinary diligence to protect the lives and persons of his passengers but is not liable for injuries to them after having used such diligence.” OCGA § 46-9-132.

3 uses to look out the window; close the door and his window; sit down in the train and

then he can move the railcar. It is within the discretion of the operator when to take

off after the doors close and the time can vary depending on the station, the number

of people getting on and off, the weather, the time of day, and which line. The

representative further explained that most of the systems are automated, but that

sometimes rail control in Chamblee may indicate a yellow or red signal meaning that

the train is not cleared to proceed. He also explained acceleration of MARTA trains,

testifying that “the way the train pulls off, it pulls off slowly, you know. The speed

is not immediate. So it slowly pulls off from the station, and then it goes to a certain

amount of speed.”

A second MARTA 30 (b) (6) representative testified that it is the train

operator’s job to make sure that everyone boards the train safely before they close the

door: “[T]heir job is to have their head out looking down the platform. Now, each car

is 75 feet long, so for six cars [that] is 450 feet. The platform is 600 feet. So they’re

looking down the platform to make sure that everyone gets on safely before they close

the doors.” When asked how long is it before the train takes off once the doors close,

the representative testified as follows:

4 I don’t know the exact time, but typically what happens is that when the operator hits the door close button, there’s a chime, an audible chime, that lets everybody know that the doors are about to close. There’s also [an] indicator light above each car, above each door, that will flash so that the hearing impaired will know that the doors are about to close. . . . And so once the operator closes the door and hits what he calls an automatic start button, there’s a delay. I don’t [know] how many seconds that it is, but it’s an automatic one. So he hits the start button. Once the doors close, there’s a few-second delay, and then the train gradually picks up speed. And I don’t know what that speed is, but, you know, it’s probably, like, maybe five or ten miles an hour. And it gradually picks up speed, and that is computer-generated — automated.

The representative acknowledged that there are no rules or regulations or systems in

place to make sure that riders are “either seated or otherwise holding onto something

so they’re secure before the train takes off.” As the representative explained, the

trains are 75 feet per car, so there is no way for the operator to know that everyone

is seated, and many times, particularly during rush hour, some people do not sit:

[I]t’s understood once you get on a train and the doors are closing, we’re about to take off.

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Metropolitan Atlanta Rapid Transit Authority v. Norman Brown, Counsel Stack Legal Research, https://law.counselstack.com/opinion/metropolitan-atlanta-rapid-transit-authority-v-norman-brown-gactapp-2022.