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Florida Third DCA affirms summary judgment for Miami-Dade County in negligence case involving injury to passenger ofCounty-operated bus, ruling that bus driver’s sudden stop did not suffice to show violation of the carrier’s duty

On April 13, 2022, in Ramos v. Miami-Dade County, etc., No. 3D21-757, the Florida Third DCA issued a per curiam affirmance of a summary judgment in favor of the defendant Miami-Dade County in a case involving a bus passenger who was allegedly injured when the bus came to a sudden stop. The trial court’s summary judgment order stated that the case was controlled by the holdings of Miami Transit Co. v. Ford, 159 So. 2d 261, 262 (Fla. 3d DCA 1964) and Artigas v. Allstate Ins. Co., 541 So. 2d 739, 740 (Fla. 3d DCA 1989). The Third DCA agreed, quoting Miami Transit Co. v Ford, 159 So. 2d at 262, in finding that there was not a “stop of extraordinary violence” and there was no other evidence relating to the stop “of some act of commission or omission by the driver which together with the sudden stop would suffice to show a violation of the carrier’s duty.”