135 A.3d 807
D.C.2016Background
- Reeves slipped inside the Archives Metro station on Feb. 24, 2011 around 5:30 pm and sued WMATA for negligence.
- Plaintiff alleged the floor tiles were unsafe and WMATA failed to warn of the hazard, proximately causing her injuries.
- WMATA moved for summary judgment arguing no unreasonably dangerous condition and no duty to warn.
- Dr. Harrison testified the floor’s coefficient of friction was well below .5 (approximately .3–.35) and that tiles were slippery when wet.
- Reeves opposed with evidence including Reeves’ deposition, Harrison affidavit, and other materials suggesting WMATA knew or should have known of the wet-floor risk.
- Trial court granted summary judgment citing Barksdale-Showell and lack of duty to warn; Reeves appealed seeking reversal and remand.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a wet Metro floor is a dangerous condition requiring warning | Reeves argues the wet floor was not open and obvious and posed a danger not equally known to WMATA | WMATA contends the wet floor was not a dangerous condition and Reeves had equal or greater knowledge | Not resolved here; appellate court finds triable issue as to danger and notice |
| Whether WMATA had a duty to warn given notice and foreseeability | Reeves argues WMATA had actual/constructive notice and failed to warn | WMATA argues no duty to warn if danger is obvious or equally known | Court concludes the duty to warn may exist; genuine issues of material fact remain regarding notice and foreseeability |
| Whether there was sufficient notice and causation to support summary judgment reversal | Reeves contends evidence shows WMATA knew or should have known of wet conditions | WMATA asserts lack of notice or causal link to fall | Vacate and remand for trial; issues of notice, foreseeability, and causation are for the jury to resolve |
Key Cases Cited
- Barksdale-Showell v. WMATA, 965 A.2d 24 (D.C. 2009) (duty to warn hinges on whether condition and risk are open and obvious to plaintiff; uniquely foreseen risks to defendant)
- Harris v. H.G. Smithy Co., Inc., 429 F.2d 744 (D.C. Cir. 1970) (notice for foreseeable hazards from rain; slip risks from wet floors)
- Wilson v. Washington Metro. Area Transit Auth., 912 A.2d 1186 (D.C. 2006) (causation and warnings in WMATA context; factual sufficiency at summary judgment)
- Tolu v. Ayodeji, 945 A.2d 596 (D.C. 2008) (causation in premises liability; jury questions on foreseeability)