Taylor v. Washington Metropolitan Area Transit Authority
CourtDistrict Court, District of Columbia
Date FiledOctober 26, 2026
DocketCivil Action No. 2025-4143
JudgeJudge Emmet G. Sullivan
StatusPublished
📰 News Coverage: Read the LAWS.com news report on this case
Full Opinion
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
MIQUET TAYLOR,
Plaintiff,
v.
Civil Action No. 25-4143 (EGS)
WASHINGTON METROPOLITAN
AREA TRANSIT AUTHORITY,
Defendant.
MEMORANDUM OPINION AND ORDER
This case arises from an accident that occurred on a
Metrobus on July 8, 2025. 1 Plaintiff Miquet Taylor (“Ms. Taylor”)
was a passenger on a Metrobus operated by Defendant Washington
Metropolitan Area Transit Authority (“WMATA”). Compl., ECF No.
1-4 ¶ 2. 2 She alleges that she was injured when the driver
“initiate[d] the handicap ramp and caus[ed] it to collide and
hit [her] leg, causing [her] to sustain serious personal
injuries.” Id. Ms. Taylor alleges that she injured her right
ankle and right shin due to the accident. Id. ¶ 5.
1 The date of the accident alleged in the Complaint is January 8,
2025. See Compl., ECF No. 1-4 ¶ 2. However, the parties agree
that this was an error and the correct date of the accident is
July 8, 2025. See Reply to Counterstatement, ECF No. 13 at 3.
2 When citing electronic filings throughout this Opinion, the
Court refers to the ECF page numbers, not the page numbers of
the filed documents.
1
Pending before the Court is WMATA’s Motion for Summary
Judgment. See Mot. for Summ. J. (“Mot.”), ECF No. 6. For the
reasons explained below, the Court DENIES WMATA’s motion.
I. Factual and Procedural Background
As a preliminary matter, because the Court is considering
WMATA’s Motion for Summary Judgment, it will construe the facts
in light most favorable to Ms. Taylor. See Holcomb v. Powell,
433 F.3d 889, 895 (D.C. Cir. 2006). However, because there is
video evidence in this case that the parties agree has not been
altered, the Court must also “view[] the facts in the light
depicted by the videotape.” Scott v. Harris, 550 U.S. 372, 381
(2007); see also Thomas v. Wash. Metro. Area Transit Auth., Case
No. 8:25-cv-00145-TJS, 2025 WL 2781481, at *3 (D. Md. Sept. 29,
2025) (“When there is videographic evidence that the parties
agree has not been altered, the court should view that evidence
to ensure the facts as alleged by the nonmoving are not
inconsistent with the facts captured by an unaltered video.”
(citation modified)).
On the date of the accident, Ms. Taylor was a passenger on
a Metrobus. See Counterstatement, ECF No. 12 ¶ 1. Prior to
exiting the bus, Ms. Taylor is seen in the video footage bending
down behind the driver in the entryway of the bus. Id. ¶ 3;
Exhibit 1 to Mot. (“Video”), ECF No. 6-1 at 1:19. Two seconds
later, while Ms. Taylor is still bent down, the warning system
2
for the wheelchair lift activates. See Video, ECF No. 6-1 at
1:21. 3 One second later, Ms. Taylor stood up, approached the exit
of the bus, and walked into the wheelchair lift. See id. at
1:22.
Ms. Taylor filed her Complaint in the Superior Court of the
District of Columbia on November 5, 2025. See Taylor v. Wash.
Metro. Area Transit Auth., 2025-CAB-007351 (D.C. Super. Ct. Nov.
5, 2025). WMATA removed the case to this Court on November 26,
2025. See Notice of Removal, ECF No. 1. On December 4, 2025,
WMATA filed their Motion for Summary Judgment. See Mot., ECF No.
6. Ms. Taylor filed her Opposition to the Motion for Summary
Judgment on December 16, 2025. See Pl.’s Resp. to Def.’s Mot.
for Summ. J. & Req. for Hr’g (“Opp’n”), ECF No. 8, 9. The same
day, Ms. Taylor filed an errata that included the exhibit to
which she refers in her Opposition. See Errata, ECF No. 10. On
December 23, 2025, WMATA filed their reply. See Reply to Pl.’s
Opp’n to Def.’s Mot. for Summ. J. (“Reply”), ECF No. 11.
On October 7, 2026, pursuant to the Court’s Minute Order,
see Order (Sept. 23, 2026); Ms. Taylor filed her Counter
3 In their original Statement of Material Facts Not in Dispute,
see ECF No. 6-2; WMATA states that the beeping is audible at
1:19. However, in their reply to Ms. Taylor’s Counterstatement,
it denies that it was audible at 1:19 and states that it was
audible at 1:21. See Reply to Counterstatement, ECF No. 13 ¶ 4.
The Court will continue to use the corrected timestamps when
referring to the video evidence, which the Court has
independently corroborated.
3
Statement of Disputed Facts. See Counterstatement of Disputed
Facts (“Counterstatement”), ECF No. 12. The same day, WMATA
filed their Reply to Ms. Taylor’s Counterstatement of Disputed
Facts. See Reply to Pl.’s Counterstatement of Disputed Facts
(“Reply to Counterstatement”), ECF No. 13.
The motion is ripe and ready for the Court’s adjudication.
II. Legal Standard
Summary judgment is proper when “there is no genuine
dispute as to any material fact and the movant is entitled to
judgment as a matter of law.” FED. R. CIV. P. 56(a). A “material”
fact is one that could “affect the outcome of the suit under the
governing law.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242,
248 (1986). A dispute is “genuine” if “the evidence is such that
a reasonable jury could return a verdict for the nonmoving
party.” Id. The moving party bears the burden of “informing the
district court of the basis for its motion” as well as
“identifying those portions of the pleadings, depositions,
answers to interrogatories, and admissions on file, together
with the affidavits, if any, which it believes demonstrate the
absence of a genuine issue of material fact.” Celotex Corp. v.
Catrett, 477 U.S. 317, 323 (1986) (internal quotation marks
omitted); see also FED. R. CIV. P. 56(c)(1)(A).
To defeat summary judgment, the nonmoving party must “go
beyond the pleadings” and “designate specific facts showing that
4
there is a genuine issue [of material fact] for trial.” Celotex
Corp., 477 U.S. at 324 (internal quotation marks omitted). In
evaluating a summary judgment motion, “[t]he evidence of the
nonmovant is to be believed, and all justifiable inferences are
to be drawn in his favor.” Anderson, 477 U.S. at 255. However,
the nonmoving party's opposition “must consist of more than mere
unsupported allegations or denials and must be supported by
affidavits or other competent evidence” in the record. Musgrove
v. District of Columbia, 775 F. Supp. 2d 158, 164 (D.D.C. 2011);
see also Celotex Corp., 477 U.S. at 324. If the evidence
favoring the nonmoving party is “merely colorable, or is not
significantly probative, summary judgment may be granted.”
Anderson, 477 U.S. at 249–50 (internal citations omitted).
“[W]here video evidence is available, if a nonmoving party at
summary judgment adopts a position blatantly contradicted by the
record, so that no reasonable jury could believe it, a court
should not adopt that version of the facts for purposes of
summary judgment.” Scott, 550 U.S. at 380.
III. Analysis
A. There is a Genuine Dispute of Material Fact as to
Whether Ms. Taylor was Contributorily Negligent
WMATA argues that Ms. Taylor was contributorily negligent
and therefore cannot recover for her injuries. See Mot. for
Summ. J., ECF No. 6-1 at 3–4. Ms. Taylor disagrees, reasoning
5
that based on the evidence provided by WMATA, a reasonable
factfinder could conclude that she was not contributorily
negligent. See Opp’n, ECF No. 9 at 6.
“Contributory negligence is conduct which falls below the
standard to which a plaintiff should conform for his own
protection.” Wash. Metro. Area Transit Auth. v. Cross, 849 A.2d
1021, 1024 (D.C. 2004) (citation omitted). In the District of
Columbia, “the contributory negligence of the plaintiff is a
complete bar to recovery.” Elam v. Ethical Prescription
Pharmacy, Inc. 422 A.2d 1288, 1289 n.2 (D.C. 1980). The question
of contributory negligence “is almost always a question of fact
for the jury.” Smith v. Wash. Sheraton Corp., 135 F.3d 779, 786
(D.C. Cir. 1998). “Only in exceptional cases, where the facts
are undisputed and where but one reasonable inference can be
drawn, is the trial court justified in holding that . . .
contributory negligence has been established as a matter of
law.” Singer v. Doyle, 236 A.2d 436, 437 (D.C. 1967).
The Court disagrees that the video, which is the only
evidence provided by WMATA in support of their Motion for
Summary Judgment, is evidence that is “so clear and undisputed
that fair-minded men can draw only one conclusion.” See Mot.,
ECF No. 6-1 at 4 (citing Mahnke v. Wash. Metro. Area Transit
Auth., 821 F. Supp. 2d 125, 132–33 (D.D.C. 2011) (citation
modified)).
6
First, the video does not show the wheelchair lift itself.
See generally Video, ECF No. 6-1. In her Opposition, Ms. Taylor
argues that another passenger exited the bus ahead of her, and
that “[s]he had no reason to believe that between the exit of
the first passenger and her attempted exit there would be
deployment of the wheelchair ramp,” but that the driver deployed
the ramp “so quickly” after the first passenger exited that she
had “no indication that exiting the bus was not ‘business as
usual.’” Opp’n, ECF No. 9 at 6. In response, WMATA states that
Ms. Taylor offered “conclusory statements that are not supported
by [their] video evidence,” Reply, ECF No. 11 at 3; but it is
not possible to know when the lift itself started moving or how
quickly it moved from the video alone. Without being able to see
the lift itself, the Court cannot determine what Ms. Taylor
actually saw when she was looking down while approaching the
door. See Reply to Counterstatement, ECF No. 13 ¶ 7 (noting the
disputed fact of where Ms. Taylor was looking when approaching
the exit of the bus after the warning sound played). Second,
from the video alone, it is not clear how obvious the warning
signal was to the bus passengers. The video shows that loud
music was playing during the relevant time, and Ms. Taylor was
standing behind the bus driver’s booth at the time the warning
signal activated. See generally Video, ECF No. 6-1.
7
The Court notes that WMATA filed the Motion for Summary
Judgment before any discovery was conducted, a little over a
week after removing the case from Superior Court. See Opp’n, ECF
No. 9 at 1–2. Summary judgment is ordinarily proper “only after
the plaintiff has been given adequate time for discovery.”
Americable Int’l, Inc. v. Dep’t of Navy, 129 F.3d 1271, 1274
(D.C. Cir. 1997) (citing First Chicago Int’l v. United Exch.
Co., 836 F.2d 1375, 1380 (D.C. Cir. 1988)). The evidence
presented to the Court is insufficient to grant summary judgment
to WMATA because a reasonable factfinder could find that Ms.
Taylor was not contributorily negligent. Moreover, should the
factfinder ultimately determine that Ms. Taylor was not
contributorily negligent, she argues that because she has not
had the opportunity to conduct discovery, she cannot uncover
evidence that would support her other arguments that WMATA was
negligent. See Opp’n, ECF No. 9 at 5; see 1443 Chapin Street, LP
v. PNC Bank, 258 F.R.D. 186, 188 (D.D.C. 2009) (noting that it
would be premature to grant summary judgment before the
plaintiff “had the opportunity to uncover the necessary factual
support for [their] arguments against summary judgment”).
Although Ms. Taylor’s claims against WMATA might not
succeed, at this juncture, it is premature to grant summary
judgment to WMATA before Ms. Taylor has had the opportunity to
gather evidence to support her claims through discovery.
8
IV. Conclusion and Order
For the reasons explained above, it is hereby
ORDERED that WMATA’s Motion for Summary Judgment, ECF No.
6, is DENIED WITHOUT PREJUDICE.
SO ORDERED.
Signed: Emmet G. Sullivan
United States District Judge
October 26, 2026
9