Cameroon Whiteru v. Washington Metropolitan Area Transit Authority

Summary

**Key Legal Topics:** Common carrier duty to render aid (Restatement (Second) of Torts § 314A); contributory negligence as complete bar in D.C.; exception to contributory negligence for common carrier's post-injury duty to aid; genuine dispute of material fact regarding station inspections. **Holding:** The D.C. Circuit reversed summary judgment for WMATA, holding that a common carrier's duty under § 314A to render aid to an injured passenger—even one who negligently caused his own injuries—is not barred by the passenger's contributory negligence. Because genuine factual disputes existed over whether WMATA knew or had reason to know of the passenger's fall and failed to inspect, the case was remanded for trial.

Holdings

1. Contributory negligence does not bar recovery when a common carrier knows or has reason to know that a passenger is injured, breaches its duty to render aid, and the passenger's injuries are aggravated as a result. The common carrier's duty under Section 314A is an exception to the contributory negligence defense.

Questions Presented

1. Whether the district court erred in granting summary judgment to WMATA on the Whiteru Estate's negligence claim based on contributory negligence, given WMATA's duty as a common carrier to render aid under Section 314A of the Restatement (Second) of Torts.

Disposition

reversed_and_remanded