District of Columbia v. Singleton
41 A.3d 717
| Md. | 2012Background
- On 20 June 2008, Respondents Singleton and his eight-year-old son Jaron were passengers on a westbound Route 50 bus in Prince George's County, Maryland.
- The bus left the travel portion of the highway and became airborne, landing in a wooded area after colliding with a tree.
- Respondents sued the District of Columbia for vicarious negligence, relying on res ipsa loquitur to infer negligence due to the bus leaving the road.
- Respondents did not call the bus driver or other reasonably available witnesses in their case-in-chief, nor did they produce a police accident report or reconstruct the accident sequence.
- The circuit court granted the District’s motion for judgment at the close of Respondents’ case, ruling the evidence failed to establish a prima facie case of negligence under res ipsa loquitur.
- The Court of Special Appeals reversed, and the District sought certiorari; the Maryland Court of Appeals granted certiorari to decide whether res ipsa loquitur can be invoked in a single-vehicle accident where causation details are not recollected and other probative evidence is unavailable.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether res ipsa loquitur supports a negligence inference in a single-vehicle accident where the plaintiff cannot recall the cause and disciplinary evidence is sparse. | Respondents argued the accident’s leaving the roadway permits an inference of negligence under res ipsa. | District contends res ipsa requires clearer evidence and exclusive control, with other causes not more probable. | Res ipsa loquitur not applicable; circuit judgment proper; cannot infer negligence. |
Key Cases Cited
- Holzhauer v. Saks & Co., 346 Md. 328 (Md. 1997) (exclusive-control element; no res ipsa where other causes could be predominant)
- Dover Elevator Co. v. Swann, 334 Md. 231 (Md. 1994) (foundation of res ipsa; accident must usually imply negligence)
- Knippenberg v. Windemuth, 249 Md. 159 (Md. 1968) (res ipsa requires negligence more probable than not)
- Hanes v. State ex rel. Lamm, 236 Md. 28 (Md. 1964) (vehicle leaving roadway; not absolute threshold for res ipsa)
- Johnson v. Jackson, 245 Md. 589 (Md. 1967) (superior access to facts; equal access defeats res ipsa)
- Romero v. Brenes, 189 Md.App. 284 (Md. 2009) (vehicle left road; supportive but distinguishable evidence needed)
- Leikach v. Royal Crown Bottling Co., 261 Md. 541 (Md. 1971) (burden to show greater likelihood of defendant’s negligence)
- Andrade v. Housein, 147 Md.App. 617 (Md. 2002) (inference of negligence for following too closely; referenced re要)
- Coastal Tank Lines v. Carroll, 205 Md. 137 (Md. 1954) (early articulation of res ipsa considerations)