Jones v. National Railroad Passenger Corporation

Background

Amanda Jones sued National Railroad Passenger Corporation, Santa Cruz Metropolitan Transit District, and other defendants over an August 25, 2014 incident on a bus from Santa Cruz to San Jose. Jones was using a motorized scooter after knee surgery. The scooter tipped while she remained seated on it, causing her to fall to the floor. The driver stopped, helped Jones and the scooter, and emergency services were contacted, but Jones declined assistance.

Jones’s Third Amended Complaint asserted claims under the Americans with Disabilities Act, the Rehabilitation Act, the California Unruh Civil Rights Act, and a negligence claim. She sought declaratory and injunctive relief, damages, and attorney’s fees and costs.

The court’s October 10, 2019 order granted defendants’ motions for summary judgment. The court found that Jones had shown only a hypothetical possibility—not a realistic possibility—that she would use the same bus system again and face a similar incident, so she lacked standing for injunctive relief. It also found declaratory relief inappropriate because there was no ongoing relationship between Jones and defendants. The court further found insufficient evidence of a statutory violation or intentional discrimination supporting damages, and rejected parts of the negligence claim, including the theory that the driver was speeding.

Motion for Reconsideration

Jones asked the court to reconsider that earlier order. A motion for reconsideration asks the same court to revisit an earlier order, generally based on newly discovered evidence, clear error, or an intervening change in controlling law. The court also noted that its local rules prohibit using reconsideration to reargue matters previously presented or to introduce evidence that could reasonably have been offered earlier.

The court excused Jones’s failure to request permission before filing the motion because judgment had already been entered concurrently with the summary-judgment order.

Injunctive Relief

The court rejected Jones’s argument that defendants had not raised whether she was likely to use the same bus system again. It found that defendants’ summary-judgment briefing had addressed that issue.

Jones pointed to deposition testimony that she might travel on “Amtrak” again as a last resort. The court found that the testimony referred generally to different bus and train systems, not specifically to the Santa Cruz Metropolitan Transit District bus system. It also found the testimony showed she was unlikely to use the system again and had not submitted the testimony during the summary-judgment proceedings.

Jones also submitted a new declaration stating that she planned to return to Santa Cruz and use public transportation. The court found that this evidence could have been presented earlier and, even if considered, did not establish a real and immediate threat of future injury. The court similarly found that testimony about a separate bus incident involving a trip from Los Angeles to Oakland did not provide enough information, did not concern a Santa Cruz Metropolitan Transit District bus, and did not show likely future violations by defendants.

The court concluded that the evidence still showed only one incident on a bus operated by Santa Cruz Metropolitan Transit District. Jones therefore was not entitled to injunctive relief.

Americans with Disabilities Act Claims

The court found that Jones presented no new legal argument showing that defendants failed to train the driver as required by the relevant regulations. Although the driver testified that he had not been trained on Jones’s particular scooter, he also testified that he had been trained on regular scooters. The court stated that the regulations did not require training on every mobility device.

The court also rejected Jones’s assertion that defendants’ buses remained improperly equipped five years later because she offered no foundation for that claim. It clarified that its earlier order had not held that defendants were free to operate without securement equipment; rather, Jones had not provided credible evidence that defendants lacked adequate equipment at the time of the incident. The court relied on the regulation’s reference to securing a mobility aid in accordance with the manufacturer’s instructions and noted that Jones’s scooter manual warned against sitting on the scooter in a moving vehicle.

The court further found that the absence of an operator handbook did not establish inadequate training, particularly because Jones did not identify a rule requiring such a handbook and did not challenge the driver’s training records or statements about annual training.

Negligence Claim

The court rejected Jones’s reading that the earlier order had dismissed her negligence claim merely because parts of her complaint referred to trains and railroad tracks. Instead, the court explained that those portions of the claim failed because the evidence concerned a bus incident, not a train incident.

The court also reaffirmed that Jones’s testimony that the bus felt too fast, without other evidence that it was speeding, did not create a genuine factual dispute for a jury. Jones additionally argued that defendants negligently transported her without properly securing her scooter. The court found that this argument relied on alleged duties under the Americans with Disabilities Act, the Rehabilitation Act, and related regulations. Because Jones had not shown a breach of those statutory duties, the court found no basis to reconsider its earlier ruling. It also noted that the relevant regulations required transportation providers to use their best efforts to secure a disabled passenger, not to provide perfect service, and that the evidence did not show the driver failed to do so.

Disposition

The court denied Jones’s motion for reconsideration. The opinion did not alter the prior order granting summary judgment in favor of defendants.