Smith v. Washington Metropolitan Area Transit Authority

CourtDistrict Court, District of Columbia
DecidedMarch 3, 2026
DocketCivil Action No. 2024-3599
StatusPublished

This text of Smith v. Washington Metropolitan Area Transit Authority (Smith v. Washington Metropolitan Area Transit Authority) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Smith v. Washington Metropolitan Area Transit Authority, (D.D.C. 2026).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

____________________________________ ) ANGELA SMITH, ) ) Plaintiff, ) ) v. ) Civil Action No. 24-3599 (ABJ) ) WASHINGTON METROPOLITAN ) AREA TRANSIT AUTHORITY, ) ) Defendant. ) ____________________________________)

MEMORANDUM OPINION

Plaintiff Angela Smith brought this action against the Washington Metropolitan Area

Transit Authority (“WMATA”) alleging one claim of negligence. Compl., Ex. A to Notice of

Removal [Dkt. # 1-1] at 10–12. Plaintiff alleges that she was a passenger on a WMATA bus when

it collided with another vehicle, and that the accident caused her physical pain and mental anguish.

Compl. ¶¶ 11–16.

Plaintiff filed suit in the Superior Court of the District of Columbia on October 25, 2024,

and defendant filed a notice removing the complaint to this Court on December 24, 2024. Notice

of Removal at 1. On January 14, 2025, defendant filed a motion to dismiss or, in the alternative,

for summary judgment, which included a video of the incident. Def.’s Mot. to Dismiss, or in the

Alternative, Mot. for Summ. J. [Dkt. # 7] (“Mot.”). The motion is fully briefed. Pl.’s Mem. in

Opp. to Mot. [Dkt. # 8] (“Opp.”); Def.’s Reply in Supp. of Mot. [Dkt. # 9] (“Reply”).

For the reasons stated below, the Court will GRANT defendant’s motion for summary

judgment. The video shows that plaintiff did not suffer injury caused by any purported breach of duty, and plaintiff has not come forward with any factual material from which a reasonable

factfinder could find otherwise.

BACKGROUND

According to the complaint, on March 8, 2023, plaintiff was a passenger on WMATA bus

number 4731 when it “violently” struck another vehicle at approximately 6:15 p.m. Compl.

¶¶ 6–7; Def.’s Statement of Undisputed Material Fact [Dkt. # 7-2] (“DSUMF”) ¶ 1. Plaintiff

allegedly suffered “serious, painful, and permanent injuries to her back, neck, and other parts of

her body” as a result of the incident, and she seeks $5,000,000 in damages. Compl. ¶¶ 14–16;

DSUMF ¶ 2.

Defendant has submitted an exhibit that consists of a series of videos of the bus taken from

different angles at the same time, shown in the same window. See Ex. 2 to Mot. [Dkt. # 7-3]

(“Video”). The exhibit provides footage from nine different angles inside and outside the bus,

including: (1) left forward facing video of the exterior of the bus; (2) front to rear video of the

interior of the bus; (3) left front door video of the exterior and interior of the bus; (4) the bus

operator’s view of the interior of the bus; (5) left rear door video of the interior of the bus; (6) left

curbside rear video of the exterior of the bus; (7) left rear to front video of the interior of the bus;

(8) left street view of the exterior of the bus; and (9) left rear video of the exterior of the bus. Id.

They appear on the screen in three rows with three videos each, and the videos do not include

sound.

The eighth angle, the video at the bottom middle of the screen consisting of footage from

the left street view of the exterior of the bus, captured the accident. Video at 18:15:58–18:16:03.

It shows a silver vehicle with a black roof swerving slightly to the left to avoid oncoming traffic

from the opposite lane, and making contact with the left rear side of the bus as it goes by. Id. After

2 this glancing blow, the bus stopped briefly due to the traffic in front of it, and then continued to

drive for another one minute and eleven seconds before pulling over to the side of the road. Id. at

18:16:11–18:17:22.

The video footage from the second, third, fourth, fifth, and seventh angles show the

passengers inside the bus: what looks to be fifteen adults and three children. Id. At the time the

car made contact with the bus, a few passengers turned their heads towards the left side of the bus

as if to see what happened, but none of them were jostled or jolted or appear to be otherwise

affected by the impact. Id. at 18:16:00–08. One of the children, who was the only person standing

during the incident, appears to be entirely unaffected. Id. at 18:15:59–18:16:02.

The passengers remained on the bus until the driver pulled over. Id. at 18:16:03–18:17:23.

Once the bus came to a stop, the driver turned and spoke to the passengers, and some began to

disembark as he stepped off the bus to talk to the driver of the vehicle that hit the bus. Id. at

18:17:23–46. About a minute later, the bus driver briefly returned to the bus to speak to the

passengers that remained. Id. at 18:18:32–37. Each of the remaining passengers then walked

calmly off the bus. Id. at 18:17:37–18:19:17.

STANDARD OF REVIEW

The motion filed by the defendant was expressly designated as a motion to dismiss or for

summary judgment in the alternative, Mot. at 1, and it was accompanied by both a statement of

material facts not in dispute, see DSUMF , and the video evidence.1 Ex. 2. If “matters outside the

pleadings are presented to and not excluded by the court” on a motion to dismiss under Federal

1 It is fair to say that the statement consisting of but three material facts was not particularly detailed; the first two statements simply summarize plaintiff’s allegations, and it is only the third that asserts a fact and identifies the evidence that supports it. DSUMF ¶¶ 1–3.

3 Rule of Civil Procedure 12(b)(6), “the motion must be treated as one for summary judgment under

Rule 56.” Fed. R. Civ. P. 12(d); see Marshall Cnty. Health Care Auth. v. Shalala, 988 F.2d 1221,

1226 (D.C. Cir. 1993) (applying the same test when converting a Rule 12(b)(6) motion to one for

summary judgment). The “parties must be given a reasonable opportunity to present all the

material that is pertinent to the motion.” Fed. R. Civ. P. 12(d).

Because defendant’s motion in this case asks the Court to consider video footage of the

incident, the Court will treat the motion as one for summary judgment. Plaintiff was on notice that

defendant was seeking summary judgment and had a full opportunity to respond and to invoke

Federal Rule of Civil Procedure 56(d) if necessary.

Defendant submitted the necessary statement of material facts in dispute, Local Civ. R.

7(h)(1), and summary judgment is appropriate “if the movant shows that there is no genuine

dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed. R.

Civ. P. 56(a). The party seeking summary judgment “bears the initial responsibility of informing

the district court of the basis for its motion, and identifying those portions of the pleadings,

depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any,

which it believes demonstrate the absence of a genuine issue of material fact.” Celotex Corp. v.

Catrett, 477 U.S. 317, 323 (1986) (internal quotation marks omitted). To defeat summary

judgment, the non-moving party must “designate specific facts showing that there is a genuine

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Smith v. Washington Metropolitan Area Transit Authority, Counsel Stack Legal Research, https://law.counselstack.com/opinion/smith-v-washington-metropolitan-area-transit-authority-dcd-2026.