Robinson v. Wash. Metro. Area Transit Auth., No. 13-7077 (D.C. Cir. 2014)Annotate this Case
Bus driver Bumpass hit the brakes as he approached a stop sign. Robinson, a standing passenger on the bus, fell backward and broke her leg. Robinson sued WMATA, claiming that Bumpass violated WMATA’s standard operating procedures (SOPs) and that the “jerk” caused by Bumpass’ application of the brakes was of such extraordinary force that his negligence could be inferred. Bumpass admitted that he did not check his mirror before leaving the stop that morning. He knew there were several open seats up front, he said, and he assumed Robinson had sat down by the time he closed the doors and started driving. Robinson testified that the bus was going “fast, faster than normal buses,” and that it “was jerking and then [there] was an abrupt stop.” The district court rejected a jury award of $404,713.28. The D.C. Circuit affirmed, holding that a reasonable jury could not have decided in Robinson’s favor. Robinson failed to establish a causal relationship between Bumpass’ deviation from SOPs and her injury; unusual and extraordinary force cannot be inferred from mere descriptive adjectives and conclusions alone.