Washington Metropolitan Area Transit Authority v. Johnson
District of Columbia Court of Appeals
699 A.2d 404 (1997)
- Written by Liz Nakamura, JD
Facts
Devora Johnson, who suffered from serious mental illnesses, committed suicide by jumping in front of a train operated by the Washington Metropolitan Area Transit Authority (WMATA) (defendant). If the train’s conductor had timely deployed the train’s emergency brake, the train would not have hit Devora. However, the train conductor failed to do so, and it was later discovered that the conductor was under the influence of marijuana and cocaine at the time of the accident. Devora’s parents, Eleanor and Franklin Johnson (the Johnsons) (plaintiffs), filed a wrongful-death action against WMATA invoking the last-clear-chance doctrine, arguing that the conductor could have avoided killing Devora if he had timely deployed the emergency brake. Because of diversity of citizenship, the Johnsons’ action was heard in federal district court, with the district court applying District of Columbia law. The district court found WMATA liable. WMATA appealed to the federal District of Columbia Circuit. The circuit court certified a question to the District of Columbia Court of Appeals, the District of Columbia’s highest court, about whether, under District of Columbia law, the last-clear-chance doctrine applied even if the injured party had voluntarily assumed an unreasonable risk of injury.
Rule of Law
Issue
Holding and Reasoning (Ruiz, J.)
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