Jones v. National Railroad Passenger Corporation

Background

Amanda Jones’s complaint asserted claims under the Americans with Disabilities Act, Section 504 of the Rehabilitation Act, the California Unruh Civil Rights Act, and negligence against Amtrak, the Santa Cruz Metropolitan Transit District (SCMTD), and other defendants. After summary-judgment proceedings and an appeal to the Ninth Circuit, only the negligence claim against Amtrak and SCMTD remained.

The case went to trial in March 2023. The jury could not reach a verdict, and the court declared a mistrial. The court later granted Amtrak’s motion for judgment as a matter of law under Federal Rule of Civil Procedure 50(b). It ruled that Jones had not presented evidence from which a jury could infer that Amtrak owed her a relevant duty of care. The evidence showed that the bus driver was an SCMTD employee and included evidence about the driver’s speed, scooter securement, seat belts, warnings, and training. But the court found no sufficient evidence that Amtrak was responsible for the driver or his conduct. The negligence claim against SCMTD remained pending.

Motion and governing standard

Jones moved to amend the ruling and/or sought permission to file a motion for reconsideration. The court determined that Rule 60(b), which concerns relief from a final judgment or order, did not apply because the court had not entered a final judgment resolving all claims and parties’ rights. The court instead construed the request as a motion for leave to seek reconsideration under Civil Local Rule 7-9 and Rule 54(b).

Under Local Rule 7-9, leave may be granted when there is a material difference in fact or law that could not reasonably have been known earlier, new material facts or a change in law, or a manifest failure by the court to consider material facts or decisive legal arguments previously presented. Reconsideration is disfavored and is not a way to repeat arguments or raise evidence that could have been presented earlier.

Court’s analysis

Jones argued that the court had not fully considered that the existence of a duty was a legal question and that she had presented evidence and legal authority supporting a direct duty by Amtrak. She also challenged trial rulings concerning judicial notice of a 2020 consent decree involving Amtrak and the United States, and the requirement that she subpoena a named person to testify.

The court found no manifest failure to consider material facts or decisive legal arguments. It reasoned that Jones did not provide particular arguments explaining why those trial rulings were erroneous. Her disagreement with the rulings was not, by itself, a basis for reconsideration. The court also noted that the consent decree was dated five years after the events at issue and that Jones cited no authority showing that a duty or standard of care could be imposed retroactively based on that agreement.

The court further explained that although the existence of a duty is generally decided by the trial court as a legal matter, Jones still had to present evidence supporting a duty owed by Amtrak. The court found evidence that SCMTD employed the driver and therefore had a duty related to the driver’s conduct. By contrast, Jones did not present enough evidence about Amtrak’s relationship with the driver, the bus, or the route to establish that Amtrak had a duty covering the driver’s actions.

Jones also argued that the Americans with Disabilities Act supplied Amtrak’s duty. The court rejected that argument, stating that Jones identified no authority establishing that the ADA creates a separate duty of care supporting an independent negligence claim. The court added that, even if the ADA supplied such a duty, the court and the Ninth Circuit had already determined that Jones could not establish an ADA violation. She therefore could not relitigate that issue under the label of negligence.

Disposition

The court DENIED Jones’s Motion to Amend Judgment and/or for Leave to File a Motion for Reconsideration. The order did not resolve the remaining negligence claim against SCMTD.