The Estate of Billie Staton, et al. v. Washington Metropolitan Area Transit Authority

District Court, D. Maryland·Decided July 28, 2026·No. 8:25-cv-00879·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND (SOUTHERN DIVISION)

THE ESTATE OF BILLIE STATON, et * al., * Plaintiffs, *

Civil Action No. 8:25-cv-00879- v. * AAQ

* WASHINGTON METROPOLITAN AREA TRANSIT AUTHORITY, *

Defendant. *

******

MEMORANDUM OPINION AND ORDER This is a case concerning a man who fell while boarding a Washington Metropolitan Area Transit Authority (“WMATA”) Metro Access Vehicle. Pending before the Court is Defendant’s Motion for Summary Judgment. ECF No. 21. For the reasons stated below, Defendant’s Motion is denied. BACKGROUND On December 1, 2021, Billie Staton (“Deceased”) attempted to board WMATA’s Metro Access Vehicle. ECF No. 21-2; ECF No. 21-3, at 1. The parties agree that the Deceased fell while trying to board the handicap access lift platform. ECF No. 21-1, at 2; ECF No. 22, at 2. Defendant submitted a copy of the surveillance video taken from the Metro Access Vehicle at the time of the incident. ECF No. 21-2. Despite video evidence, the parties disagree over the events depicted in the video. Defendant maintains that the Metro Access Vehicle operator “completely lowered the wheelchair lift to the ground,” prior to the Deceased’s attempt to board the lift. ECF No. 21-1, at 2. Plaintiff contends that “the handicap access lift was never fully lowered to the ground,” causing the Deceased to trip and fall when he tried to board. ECF No. 22, at 2. Defendant maintains that the video shows the Deceased “acknowledged the raised lip of the wheelchair lift and raised his walker over the lip of the wheelchair lift,” ECF No. 21-1, at 2,

but “forgot to raise his left foot over the raised lip of the wheelchair lift,” resulting in his fall. ECF No. 21-1, at 7. Defendant argues further that when the Deceased fell, he did not contact the ground with his knees or other body parts, rather he “fell sideways into the arms of WMATA’s Metro Access operator.” ECF No. 21-1, at 2. Plaintiff argues instead that the Deceased did not “acknowledge” the raised lip of the lift platform, and that the video shows the Deceased falling onto his knees, not into the arms of a WMATA employee. ECF No. 22, at 2. Defendant avers that the WMATA Metro Access operator helped the Deceased to his feet, ECF No. 21-1, at 2, while Plaintiff maintains that the WMATA employee was not in the video frame at the time of the Deceased’s fall. ECF No. 22, at 2. The parties do agree that once the Deceased returned to standing on his feet, he successfully

boarded WMATA’s handicap lift. ECF No. 21-2, at 02:14. The parties agree further that the WMATA operator raised the handicap lift with the Deceased aboard, and the Deceased then entered WMATA’s Metro Access Vehicle. ECF No. 21-2, at 02:43-58. On or about February 14, 2025, Helen Staton, personal representative of the estate of the Deceased, brought suit in Maryland state court on behalf of herself and the estate of the Deceased, claiming a single count of negligence on the part of Defendant. ECF No. 1, at 1; ECF No. 1-4; ECF No. 3; ECF No. 21-4, at 2. On March 17, 2025, Defendant removed the case to federal court. ECF No. 1. On April 4, 2025, Defendant filed an Answer to Plaintiff’s Complaint. ECF No. 6.

2 On January 5, 2026, Defendant filed a Motion for Summary Judgment. ECF No. 21. The Motion has since been fully briefed. ECF Nos. 21, 22, 23. STANDARD OF REVIEW The Court will grant a motion for summary judgment only if there exists no genuine issue

as to any material fact and the moving party is entitled to judgment as a matter of law. Fed. R. Civ. P. 56(a); Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 250 (1986); Celotex Corp. v. Catrett, 477 U.S. 317, 322 (1986). If there are factual issues “that properly can be resolved only by a finder of fact because they may reasonably be resolved in favor of either party,” then the Court must deny the request for summary judgment. Anderson, 477 U.S. at 250; see Pulliam Inv. Co. v. Cameo Props., 810 F.2d 1282, 1286 (4th Cir. 1987); Morrison v. Nissan Motor Co., 601 F.2d 139, 141 (4th Cir. 1979); Stevens v. Howard D. Johnson Co., 181 F.2d 390, 394 (4th Cir. 1950). The moving party bears the burden of showing that there is no genuine issue of material fact. Fed. R. Civ. P. 56(a); Pulliam Inv. Co., 810 F.2d at 1286 (citing Charbonnages de France v. Smith, 597 F.2d 406, 414 (4th Cir. 1979)). When ruling on a motion for summary judgment, the court must

draw all reasonable inferences in favor of and construe the facts in the light most favorable to the nonmoving party. See Tinsley v. First Union Nat’l Bank, 155 F.3d 435, 438 (4th Cir. 1998). “A party who bears the burden of proof on a particular claim must factually support each element of his or her claim.” Scott v. United States, No. PJM-06-2777, 2007 WL 3020185, at *1 (D. Md. Feb. 23, 2007). Thus, on those issues on which the nonmoving party will have the burden of proof, it is his or her responsibility to confront the motion for summary judgment with an affidavit or other similar evidence. See Anderson, 477 U.S. at 256–57. “[I]n the face of conflicting evidence, such as competing affidavits, summary judgment ordinarily is not appropriate because

3 it is the function of the factfinder to resolve factual disputes, including matters of witness credibility.” EEOC v. Ecology Servs., Inc., 447 F. Supp. 3d 420, 437 (D. Md. 2020) (citing Black & Decker Corp. v. United States, 436 F.3d 431, 442 (4th Cir. 2006); Dennis v. Columbia Colleton Med. Ctr., Inc., 290 F.3d 639, 644-45 (4th Cir. 2002)).

ANALYSIS Defendant advances three main arguments in its Motion. First, Defendant argues that video demonstrates that it was not negligent. ECF No. 21-1, at 8. Second, Defendant argues that Plaintiff has not designated or offered any expert testimony on the national standard of care involving disabled patrons on a Metro Access Vehicle and as a result, cannot prove negligence. Id. at 4-6. Third, Defendant argues that the video demonstrates that the Deceased was contributorily negligent as a matter of law. Id. at 7-8. As discussed below, a reasonable juror could find that: 1) the video demonstrates that WMATA breached its duty to the Deceased; 2) Defendant breached the standard of care, despite the lack of an expert; and 3) the Deceased was not contributorily negligent.

I. A Reasonable Jury Could find that Defendant Breached its Duty to the Deceased. Considering the facts as presented in the video and applicable law, Plaintiff has created a genuine issue of material fact as to whether WMATA was negligent. To prevail in a negligence action, the plaintiff must prove: “1) that the defendant was under a duty to protect the plaintiff from injury, 2) that the defendant breached that duty, 3) that the plaintiff suffered actual injury or loss, and 4) that the loss or injury proximately resulted from the defendant’s breach of the duty.” Rowhouses, Inc. v. Smith, 133 A.3d 1054, 1066 (Md. 2016) (quoting Hamilton v. Kirson, 96 A.3d 714, 727 (Md. 2014)). “[C]ommon carriers, such as WMATA, owe an elevated duty of care to

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