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Coates v. Washington Metropolitan Area Transit Authority

United States District Court, District of Columbia

August 31, 2016

EARL COATES, Plaintiff
v.
WASHINGTON METROPOLITAN AREA TRANSIT AUTHORITY, Defendant

          MEMORANDUM OPINION AND ORDER

          COLLEEN KOLLAR-KOTELLY United States District Judge

         This case stems from a violent incident that occurred on a Washington Metropolitan Area Transit Authority ("WMATA") bus on August 21, 2015.[1] Plaintiff Earl Coates alleges that armed gunmen approached the bus at a bus stop and turned off its power by accessing an unlocked "shutoff panel" on the bus's exterior. The gunmen then attacked the bus, firing multiple gunshots before fleeing. Plaintiff, a passenger on the bus, was struck twice and injured. He brings this lawsuit against WMATA asserting several negligence-based causes of action, including a request for punitive damages.

         Before the Court is Defendant WMATA's [5] Motion to Dismiss. WMATA argues that Plaintiffs claims are barred by the doctrine of sovereign immunity. Specifically, WMATA argues that it is immune from negligent design claims and that the gravamen of Plaintiff s Complaint is that WMATA was negligent in designing its buses to include unlocked exterior shutoff panels. WMATA also argues that it is immune from claims for punitive damages.

         Upon consideration of the pleadings, the relevant legal authorities, and the record for purposes of this motion, the Court GRANTS IN PART and DENIES IN PART WMATA's Motion to Dismiss. The Court agrees with WMATA that Plaintiffs claims are barred by the doctrine of sovereign immunity to the extent they are premised on WMATA's use of unlocked shutoff panels on its buses. The Court also agrees with WMATA that Plaintiffs request for punitive damages is barred. However, Plaintiff s Complaint also contains allegations regarding allegedly negligent actions of WMATA's bus driver that are separate and distinct from WMATA's decision to use unlocked shutoff panels. To the extent Plaintiff s claims are based on these allegations, they are not barred by WMATA's sovereign immunity. WMATA's other arguments for dismissing these claims were raised for the first time in WMATA's [8] Reply to Plaintiffs Opposition to Defendant's Motion to Dismiss, and will not be considered at this time.

         Accordingly, WMATA's Motion to Dismiss is GRANTED IN PART and DENIED IN PART. Plaintiffs claims are DISMISSED to the extent they are predicated on the design of the shutoff panels on WMATA's buses. Plaintiffs request for punitive damages is also DISMISSED. WMATA's Motion to Dismiss is DENIED to the extent Plaintiff s claims are based on the actions of WMATA's bus driver that are unrelated to the unlocked shutoff panels.

         I. BACKGROUND

         For the purposes of the motion before the Court, the Court accepts as true the well-pleaded allegations in Plaintiffs Complaint. The Court does "not accept as true, however, the plaintiffs legal conclusions or inferences that are unsupported by the facts alleged." Ralls Corp. v. Comm. on Foreign Inv. in U.S., 758 F.3d 296, 315 (D.C. Cir. 2014). The Court recites only the background necessary for the Court's resolution of the pending Motion to Dismiss.

         On August 21, 2015, Plaintiff was a passenger on a WMATA bus travelling on the W8 Anacostia Loop route in Washington, D.C. Compl., ECF No. 1-3, ¶¶ 6-7. After making what appeared to be a normal stop, the WMATA bus driver opened the door for an individual waiting at the bus stop. Id. ¶¶ 8-9. The individual refused to board the bus, and the WMATA driver eventually closed the door. Id. ¶ 10. Before the bus could drive away, however, another individual disabled the bus by accessing the shutoff panel on its exterior. Id. ¶¶ 11-12. The shutoff panels on WMATA's buses are unlocked and labeled with the words "Battery Disconnect Switch Inside." Id.¶ 13.

         After the bus's power was cut off, the bus driver left the bus, leaving the bus passengers "stranded" in the dark. Id. ¶¶ 14, 30. The driver did not inform the passengers about the situation. Id. ¶ 30. The driver "abandon[ed] the bus" and made no attempt to turn the bus's power back on. Id. ¶¶ 15, 30. While the passengers were waiting on the bus in the dark, an individual fired a gun into the bus, striking Plaintiff twice. Id. ¶¶ 17, 19. The bus driver did not attempt to contact any authorities or officials to report the situation. Id. ¶ 30.

         Based on these allegations, Plaintiff asserts several negligence-based causes of action, including a request for punitive damages. Id. ¶¶ 24-42. WMATA moves to dismiss under Federal Rules of Procedure 12(b)(1) and 12(b)(6).

         II. LEGAL STANDARD

         A. Federal Rule of Civil Procedure 12(b)(1)

         Under Rule 12(b)(1), the plaintiff bears the burden of establishing that the court has subject matter jurisdiction. Georgiades v. Martin-Trigona, 729 F.2d 831, 833 n.4 (D.C. Cir. 1984) ("It is the burden of the party claiming subject matter jurisdiction to demonstrate that it exists."). A court must accept as true all factual allegations contained in the complaint when reviewing a motion to dismiss pursuant to Rule 12(b)(1). Banneker Ventures, LLC v. Graham, 798 F.3d 1119, 1129 (D.C. Cir. 2015) ("As it must on motions to dismiss for failure to state a claim, a district court considering a motion to dismiss for lack of subject matter jurisdiction accepts the allegations of the complaint as true."). "Where necessary to resolve a jurisdictional challenge under Rule 12(b)(1), 'the court may consider the complaint supplemented by undisputed facts evidenced in the record, or the complaint supplemented by undisputed facts plus the court's resolution of disputed facts.'" Id. (quoting Herbert v. Nat'l Acad, of Scis., 974 F.2d 192, 197 (D.C. Cir. 1992)).

         B. Federal Rule of Civil Procedure 12(b)(6)

         Under Rule 12(b)(6), a party may move to dismiss a complaint on the grounds that it "fail[s] to state a claim upon which relief can be granted." Fed.R.Civ.P. 12(b)(6). "[A] complaint [does not] suffice if it tenders 'naked assertion[s]' devoid of 'further factual enhancement.'" Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 557 (2007)). Rather, a complaint must contain sufficient factual allegations that, if accepted as true, "state a claim to relief that is plausible on its face." Twombly, 550 U.S. at 570. "A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged." Iqbal, 556 U.S. at 678. In deciding a Rule 12(b)(6) motion, a court may consider "the facts alleged in the complaint, documents attached as exhibits or incorporated by reference in the complaint, " or "documents upon which the plaintiffs complaint necessarily relies even if the document is produced not by the plaintiff in the complaint but by the defendant in a motion to dismiss." Ward v. District of Columbia Dep't of Youth Rehab. Servs., 768F.Supp.2d 117, 119 (D.D.C. 2011) (citations omitted).

         III. DISCUSSION

         WMATA argues that Plaintiffs claims are barred by the doctrine of sovereign immunity. As explained in more detail below, the Court agrees that Plaintiff s claims are barred by sovereign immunity to the extent they are factually premised on WMATA's use of unlocked shutoff panels on its buses. However, the Court concludes that Plaintiffs claims are not barred to the extent they are premised on allegedly negligent actions of WMATA's bus driver. The Court will not consider WMATA's other arguments for dismissing such claims, as they were raised for the first time in WMATA's Reply brief. Finally, the Court agrees with WMATA that Plaintiffs request for punitive damages is barred.

         A. WMATA's Sovereign ...


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