Tripmacher v. Starwood Hotels & Resorts Worldwide, Inc.
277 F. Supp. 3d 104
| D.D.C. | 2017Background
- Karyn Tripmacher (plaintiff) tripped and fell at a wedding reception at the St. Regis Hotel, suffering serious injuries; she sued Starwood for negligence in D.C. Superior Court and the case was removed to federal court on diversity grounds.
- The alleged cause was a temporary wheelchair ramp (≈5 ft wide, ≈26 in long, ~4–5 in high, carpeted to match ballroom floor, yellow tape on edges, no handrails) placed near double doors between the Astor Ballroom and the Astor Terrace.
- No eyewitnesses to the fall; plaintiff concedes she did not see the ramp when she fell but insists she tripped over it; a family member corroborated seeing no other hazard.
- The ballroom was crowded and dimly lit during the reception; hotel testimony indicates lights were dimmed to ~50%.
- The court’s scheduling order required expert designations; plaintiff missed the initial deadline and a renewed deadline and did not timely designate any expert; a late-file request was denied.
- Defendant moved for summary judgment arguing that under D.C. law plaintiff needed expert proof of the applicable standard of care and she had no expert; the court granted summary judgment for defendant.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether expert testimony was required to establish the applicable standard of care | Tripmacher: no expert needed; jurors can use common experience to assess ramp danger, lighting, crowding, and design defects | Starwood: D.C. law requires expert testimony where issues are beyond lay jurors' knowledge (design, engineering, adequate lighting, crowd control) | Expert testimony required; plaintiff produced none, so cannot prove standard of care |
| Whether lay jurors can assess ramp specifications (size, color, lack of handrails, yellow tape contrast) | Ramp features are obvious hazards within jurors’ common knowledge | Ramp design and construction issues are related to engineering/construction and require expert proof | Ramp-spec issues require expert testimony; lay opinion insufficient |
| Whether lay jurors can determine adequacy of ballroom lighting | Plaintiff: jurors can decide if lighting was too dim | Defendant: illumination standards are technical and require expert evidence | Adequacy of lighting requires expert testimony; lay testimony insufficient |
| Whether crowding and placement of accessibility features can be judged by jurors | Plaintiff: common experience with crowded events suffices to assess danger | Defendant: planning, placement, and crowd-control considerations are specialized and need expert proof | Crowd-management and placement issues require expert testimony |
Key Cases Cited
- Woods v. District of Columbia, 63 A.3d 551 (D.C. 2013) (elements of negligence under D.C. law)
- Night & Day Mgmt., LLC v. Butler, 101 A.3d 1033 (D.C. 2014) (expert required when issue is beyond lay juror knowledge)
- Varner v. District of Columbia, 891 A.2d 260 (D.C. 2006) (collecting cases requiring expert testimony in premises-safety contexts)
- Hill v. Metropolitan A.M.E. Church, 779 A.2d 906 (D.C. 2001) (expert required for planning/handling of large crowds)
- Briggs v. Wash. Metro. Area Transit Auth., 481 F.3d 839 (D.C. Cir. 2007) (expert required to prove adequate illumination standards)
- Burke v. Air Serv Int'l, Inc., 685 F.3d 1102 (D.C. Cir. 2012) (affirming summary judgment where plaintiff failed to designate required expert)