Williams v. United States

CourtDistrict Court, W.D. Washington
DecidedJuly 30, 2024
Docket3:22-cv-05640
StatusUnknown

This text of Williams v. United States (Williams v. United States) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Williams v. United States, (W.D. Wash. 2024).

Opinion

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4 5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT TACOMA 7 WILLIAMS et al, Case No. 3:22-cv-05640-TMC 8 Plaintiff, ORDER ON DEFENDANT’S MOTION TO 9 DISMISS AND PLAINTIFFS’ MOTION v. FOR SUMMARY JUDGMENT 10 UNITED STATES OF AMERICA, 11 Defendant. 12 13

14 I. INTRODUCTION 15 Plaintiff Harry Williams sued Defendant the United States of America under the Federal 16 Tort Claims Act (FTCA), alleging that the negligence of Oregon Army National Guard officers 17 while planning and conducting a training exercise started a fire that obscured visibility on 18 Interstate 82, causing Williams to crash his motorcycle and suffer severe injuries. The United 19 States has moved to dismiss (Dkt. 16), arguing that Williams’s claims present nonjusticiable 20 political questions and that it is immune from suit. Williams has moved for partial summary 21 judgment (Dkt. 21), arguing there is no genuine dispute of material fact that the United States 22 was negligent and the sole cause of his injuries. 23 The Court GRANTS IN PART and DENIES IN PART the United States’ motion to 24 dismiss. Williams has stipulated to the dismissal of his strict liability claims. While Williams’s 1 negligence claims are justiciable, several of his theories are barred by the discretionary function 2 exception to the FTCA. Williams’s surviving allegations concern whether the officers’ use of 3 explosive devices during the exercise (1) complied with the mandatory fire prevention policy in

4 place at the Umatilla Chemical Depot training range; (2) followed the safety protocol to control 5 fire hazards stated in the officers’ risk assessment for the training; and (3) negligently deviated 6 from the plan to keep local firefighters updated on the use of explosive devices. 7 The Court DENIES Williams’s motion for summary judgment. The United States has 8 pointed to sufficient evidence in the record to create a genuine factual dispute as to (1) whether 9 its officers were negligent; and (2) whether Williams is responsible for any comparative fault. 10 In his reply in support of his motion for summary judgment, Williams also moved to 11 strike (1) the declaration of Lieutenant Colonel Timothy X. Merritt for late disclosure and lack of 12 personal knowledge and (2) the testimony of defense expert Ronald Sanders for lacking

13 foundation. Dkt. 41. Williams’s motion to strike Merritt’s declaration is moot because the 14 Court’s does not rely on Merritt’s testimony. And Williams’s motion to strike Sanders’s 15 testimony is improper because it should have been brought as a Daubert motion by the 16 dispositive motion deadline. The Court DENIES both motions to strike. 17 II. BACKGROUND 18 A. The training exercise and motorcycle accident On May 23, 2016, Harry Williams was riding his motorcycle southbound with a group of 19 friends on Interstate 82. Dkt. 1-1 at 2; Dkt. 24 at 1. Interstate 82 borders the United States 20 Army’s Umatilla Chemical Depot where, on that day, the Oregon National Guard was 21 conducting a field training exercise. Dkt. 1-1 at 2; see Dkt. 17-10 at 2–4; Dkt. 17-13 at 2. 22 Around 8:05 a.m., Sergeants First Class (SFC) Ryan Austin and Jeremy Greene were 23 leading the exercise and initiated a simulated sniper attack on the training cohort while they were 24 1 on a two lane asphalt road at Umatilla, surrounded by dry grass. Dkt. 19-14 at 2; Dkt. 19-15 at 4. 2 The trainees requested an artillery strike on the sniper and SFCs Austin and Greene threw 3 explosive “artillery simulator” rounds onto the road. Id. One of SFC Greene’s rounds “bounced a

4 couple times and rolled off the concrete and into the grass” where it exploded and started a brush 5 fire. See id. 6 SFCs Austin and Greene ceased training and commanded the trainees to begin fire 7 suppression, “stomping out the fire” until Oregon Military Department (OMD) firefighters 8 arrived. See id. Around 8:18 a.m., SFC Austin called Master Sergeant (MS) Alan Fruitt at 9 Umatilla Range Control to report the fire. See Dkt. 19-2 at 26–27. MS Fruitt called OMD fire 10 suppression officer Benjamin Beyers to report that the training cohort had started a fire. Dkt. 19- 11 9 at 22. By the time Officer Beyers and other OMD firefighters arrived, the fire had reached 12 about five acres in size. Id. at 24.

13 By 10:25 a.m., the local fire marshal had been alerted to the fire. Dkt. 17-13 at 3; Dkt. 22 14 at 1. The fire marshal conferred with the Oregon Department of Transportation (ODOT) and 15 decided to shut down Interstate 82 because the fire was approaching the freeway and could 16 impact visibility on the road. Dkt. 22 at 1–2. At 11:00 a.m., ODOT Coordinator Gene Carbert 17 began closing Interstate 82 by putting up a sign and setting cones at Exit 5. Id. at 2. But smoke 18 from the fire had reached the freeway and some collisions had already occurred. Id. 19 Just before the freeway closed, Williams and his friends neared Exit 5. Dkt. 23 at 3; Dkt. 20 24 at 2. Williams was leading the group when the wind shifted and blew thick smoke onto the 21 freeway. Id. Visibility dropped. Dkt. 27-20 at 10–11; see Dkt. 27-23 at 4–5. Williams crashed 22 into a Mini Cooper traveling ahead of his group and was sent flying off his motorcycle. Id. at 11.

23 Williams lost consciousness and woke up on the road before he was airlifted to Kadlec Regional 24 Medical Center, where he underwent emergency surgery. Dkt. 14-1 at 20. 1 B. Army guidelines for training range safety procedures 2 The United States Army sets regulations for the development and operation of training 3 ranges such as Umatilla. See generally Dkt. 19-4, 19-5. The Army training circular addressing

4 training ranges serves as “a working guide” for range development. Dkt. 30-1 at 11. The training 5 circular explains that range development projects “require careful, deliberate planning by a team 6 who coordinates the Range and Training Land Program (RTLP) process in accordance with 7 Army Regulation (AR) 210-21, Army Ranges and Training Land Program, and this circular.” Id. 8 at 15. The circular advises installation commanders to “establish range-control and safety 9 programs according to,” among others, AR 210-21. Dkt. 19-4 at 7. Commanders should also 10 appoint personnel to supervise weapons firing and enforce safety requirements. Id. 11 AR 210-21 states that installation commanders should establish procedures “for the safe 12 conduct of operations on all firing ranges.” Dkt. 19-5 at 15. The relevant chapter of AR 210-21

13 provides “recommended minimum requirements” for the conduct of “safe, efficient, and realistic 14 training.” This includes range regulations and standard operating procedures “developed and 15 tailored for application to the weapon systems fired or anticipated to be fired on the installation, 16 and the management and allocation of training areas.” Id. at 20. These procedures should 17 address, “at a minimum . . . control and coordination of training facilities, environmental 18 compliance, communications, accident reporting, fire-fighting, ammunition and munition 19 handling . . . range safety requirements and procedures, and severe weather conditions.” Id. The 20 regulation does not specify requirements beyond these broad categories. See id. 21 C. Fire prevention policies at Umatilla Chemical Depot The United States Army closed the Umatilla Chemical Depot as an active military base in 22 2012. Dkt. 17-1 at 5. The Oregon National Guard, however, maintained approximately 2,100 23 acres and several buildings for training and administrative use. Id. Umatilla had its own fire 24 1 department when it was an active base and a wildfire response plan last updated in 2010. 2 Dkt. 17-3 at 2. After Umatilla’s closure as an active base, OMD and the Hermiston Fire 3 Department were contracted to provide firefighting services. Dkt. 17-3 at 2; Dkt. 17-4 at 2–3.

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Williams v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/williams-v-united-states-wawd-2024.