The Georgia Supreme Court has denied a petition for certiorari in the case of Kadiatou Sanoh v. Metropolitan Atlanta Rapid Transit Authority (MARTA), which addresses the issue of passenger safety on public transportation. This decision affects individuals who rely on MARTA for their daily commutes, as it raises questions about the standards of care that public transit authorities must uphold to protect their passengers.
The case stems from an incident that occurred on January 22, 2022, when Kadiatou Sanoh boarded a MARTA bus. Sanoh was in the process of searching for change to pay her fare when the bus driver accelerated away from the stop. The driver then abruptly hit the brakes, causing Sanoh to fall and sustain significant injuries. The legal dispute centers on whether MARTA exercised the required level of care, known as “extraordinary diligence,” to ensure passenger safety.
The parties involved in this case are Kadiatou Sanoh, the injured passenger, and MARTA, the public transportation authority responsible for operating the bus service. Sanoh filed a lawsuit against MARTA, claiming that the driver’s actions constituted negligence and a breach of the duty of care owed to passengers. The case was initially heard in the Court of Appeals, which ruled in favor of MARTA, stating that the transit authority did not have a duty to give passengers a reasonable time to find a seat before departing.
This ruling prompted Sanoh to petition the Georgia Supreme Court for certiorari, seeking a review of the lower court's decision. The Supreme Court ultimately denied the petition on August 18, 2026, meaning the Court of Appeals' ruling stands. The decision was made with all justices concurring, except for Chief Justice Peterson and Justices Ellington, Pinson, and Land, who dissented. Justice Colvin was disqualified from the case.
In the dissenting opinion, Justice Pinson emphasized the importance of the duty of extraordinary diligence that MARTA, as a carrier of passengers, is required to uphold. He argued that the question of whether MARTA breached this duty should be determined by a jury, rather than being dismissed as a matter of law. He pointed out that the Court of Appeals' ruling effectively shielded MARTA from liability for potential negligence in situations where a passenger may not have had enough time to secure themselves before the bus departed.
The dissent noted, "There can be no real dispute that MARTA owes a duty of extraordinary diligence to protect its passengers... the real question was whether MARTA had breached that duty under the circumstances of this case."
Justice Pinson also raised hypothetical scenarios where a bus driver might act recklessly, such as accelerating immediately after closing the doors or failing to wait for elderly or disabled passengers to be seated. He argued that these situations should be evaluated by a jury to determine if the driver acted with the necessary care expected under the law.
The impact of this ruling is significant for public transportation authorities and passengers alike. By denying the petition for certiorari, the Georgia Supreme Court has upheld the Court of Appeals' interpretation of the duty of care owed by MARTA. This decision may set a precedent that limits the liability of public transport systems in similar cases where passengers are injured due to abrupt stops or starts.
As a result, passengers may face challenges in seeking compensation for injuries sustained while using public transportation. The ruling suggests that unless there are clear and indisputable circumstances of negligence, transit authorities may not be held liable for injuries that occur during normal operations.
Looking ahead, it is unclear if the ruling can be appealed further, as the Supreme Court has already denied review. However, there may be related cases pending that could address similar issues of liability and duty of care in the context of public transportation. Legal experts will likely continue to monitor how this case influences future litigation surrounding passenger safety on public transit systems.