W.O. v. United States

CourtDistrict Court, W.D. Virginia
DecidedApril 3, 2025
Docket7:24-cv-00730
StatusUnknown

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

Bluebook
W.O. v. United States, (W.D. Va. 2025).

Opinion

CLERK'S OFFICE US. DISTRICT COURT AT ROANOKE, VA IN THE UNITED STATES DISTRICT COURT FILED FOR THE WESTERN DISTRICT OF VIRGINIA cope aver cLERK ROANOKE DIVISION BY: s/ M.Poff, Deputy Clerk W.O., a minor, by his father and next ) friend, SEAN O’BRIEN, ) ) Case No. 7:24-cv-730 Plaintiff, ) ) By: Michael F. Urbanski v. ) Senior United States District Judge ) UNITED STATES OF AMERICA, ) ) Defendant. MEMORANDUM OPINION On July 20, 2023, W.O., then nine years old, and his family visited the John Kerr Dam and Reservoir in Boydton, Virginia. Compl., ECF No. 1, J 4. W.O. fell while swinging on a playground swing set and was injured. Id. ff] 16-17. W.O., by and through his father, filed a complaint on October 22, 2024, under the Federal Tort Claims Act (“FTCA”), alleging that the United States, which maintains John Kerr Dam and Reservoir through the United States Army Corps of Engineers (“USACE”), breached its duty of care owed to park visitors by negligently inspecting and failing to repair the swing set. Id. 4] 15. Specifically, W.O. alleges that a USACE employee inspected the swing set in April 2023, three months before W.O.’s accident, and completed a checklist indicating that the playground equipment was entirely safe and “compliant,” despite evident problems with the swing set’s S-hook. Id. {| 9. The United States moved to dismiss for lack of subject matter jurisdiction and for failure to state a claim on January 13, 2025. ECP No. 8. The United States principally contends that the United States had a contract with an independent contractor, FedServ, Inc. (“FedServ”), for the maintenance of John Kerr Dam and Reservoir, including the swing set,

and that therefore, both the independent contractor and discretionary function exceptions to the FTCA’s waiver of sovereign immunity apply. However, because neither exception applies to the negligence W.O. alleges based on the affirmative acts of an employee of the United

States during the inspection in April 2023, the motion to dismiss for lack of subject matter jurisdiction must be DENIED in part as to W.O.’s claims centering on that inspection and GRANTED in part as to W.O.’s claims based on USACE’s generalized inaction. The motion to dismiss for failure to state a claim must be DENIED because the complaint plausibly alleges that USACE’s negligence during the inspection in April 2023 caused W.O.’s accident. BACKGROUND

USACE installed the swing set at issue in this case in 1990 as part of a playground at John Kerr Dam and Reservoir. Compl., ECF No. 1, ¶¶ 4, 5, 6. In April 2023, three months before W.O.’s accident, a USACE employee, Alyson Parker, who served as the site’s collateral duty safety officer, inspected the swing set as part of the “opening” of the campground for the season (“April 2023 Parker Inspection”). Id. ¶ 9.1 Parker completed this inspection pursuant to a standard operating procedure, “SOP for Playground Safety at Wilmington

District Lakes,” which suggests that the collateral duty safety officer should be trained in playground inspection via the Certified Playground Safety Inspector and, once trained, “should assist with playground inspections on a regular basis.” See SOP for Playground Safety at Wilmington District Lakes, ECF No. 11-2. During her inspection, Parker completed a “Playground Inspection Checklist,” on which Parker deemed the equipment “compliant”

1 The Playground Inspection Checklist, which was attached to W.O.’s brief in opposition to the motion to dismiss, indicates that Parker’s inspection was an “opening” inspection, as opposed to a “monthly” or “random” inspection. ECF No. 10-1. when inspected for “[v]isible [c]racks, [b]ending, [w]arping, [r]usting, . . . [b]reakage of [a]ny [c]omponent, . . . [d]eformation of [o]pen [h]ooks, [s]hackles, [r]ings, [l]inks, etc.[,]” or a “[w]orn [s]wing [h]anger and [c]hains.” Compl., ECF No. 1, ¶ 9; see also Playground

Inspection Checklist, ECF No. 10-1. USACE contracts with FedServ to “procure for the Government complete and efficient maintenance and repairs on the John H. Kerr Project.” FedServ Contract, ECF No. 11-1 at 24 ¶ TP-1.1. Specifically, “The Contractor shall provide inspections, maintain and repair up to ten (10) playground areas throughout the project,” with pertinent work to include “repairing or removing from service damaged playground equipment, park benches, borders

or wooden timbers” and “inspect[ing] playground equipment from top to bottom for wear, structural integrity, and parts replacement.” Id. at 60 ¶ TP-5.9. An affidavit attached to W.O.’s opposition to the motion to dismiss states: FedServ, Inc. conducted biweekly inspections of the Campground and playground equipment therein. FedServ, Inc. employees completed an inspection of the swing set at the Campground on 11 July, 2023 and submitted an inspection report documenting their findings. The inspection report contained no notes of needed inspection, indicating that on the date of their inspection they observed no defect in or needed maintenance of examined playground equipment.

Declaration of Tasha Alexander, ECF No. 10-3, ¶ 7. FedServ’s July 11, 2023, inspection occurred nine days prior to W.O.’s accident. On July 20, 2023, W.O. was injured while “using the swing set in an appropriate and foreseeable manner.” Compl., ECF No. 1, ¶ 15. “While swinging forward, the swing’s triangular seat bracket disengaged from the support chain because the metal S-hook was worn, deformed and open.” Id. W.O. fell and suffered injuries requiring “emergency and subsequent medical treatment, including immobilization, emergency surgery on or about July 27, 2023 to repair a displaced fracture of his right middle finger, followed by casting and physical therapy.” Id. ¶¶ 16-17. USACE’s subsequent investigation revealed that “the swing set had old, worn,

defective equipment including a worn S-hook fastener, the metal of which had become visibly thin at its natural friction point from swinging.” Id. ¶ 19. W.O. alleges that this “visibl[e]” deformity of the S-hook would have been apparent to any inspector long before W.O.’s accident, including at the time of the April 2023 Parker Inspection, had the inspector exercised ordinary care in examining the swing set. Id. ¶ 25 a. W.O., through his father, filed a timely SF95 notice of claim to the United States Army,

which was denied on April 25, 2024. Id. ¶ 21. W.O., through his father, then filed the instant complaint under the FTCA on October 22, 2024. Id. The complaint alleges that during the April 2023 Parker Inspection, a USACE employee overlooked “patent defects in violation of duties of reasonable care.” Id. ¶ 25 a. The complaint further alleges that this constituted negligence per se based on various playground safety standards that USACE has allegedly adopted. Id. ¶ 25 b.2 Additionally, the complaint alleges that USACE “failed to conduct a

timely assessment of the age and obsolescence of the components [of the swing set],” id. ¶ 25 c, that “USACE failed to conduct ongoing, proper, and regular inspections through its own employees on each patrol in 2023,” id. ¶ 25 d, that “USACE failed to timely address years of foreseeable, progressive, and visible wear and tear at the friction point between the S-hook and the seat bracket,” id. ¶ 25 e, and that “USACE’s park rangers, CE Techs, and other staff

2 For example, the complaint alleges that USACE adopted the “U.S. Consumer Playground Safety Commission’s Public Playground Safety Handbook.” Compl., ECF No. 1, ¶ 13. Evidence is needed to shed further light on this allegation. members failed to inspect the swing set properly on their patrols,” id. ¶ 25 f. W.O. claims that his injuries were a direct and proximate result of these breaches. Id. ¶ 26. STANDARD OF REVIEW

a. Federal Rule of Civil Procedure

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