Lessons Learned From Legionnaires’ Disease Litigation

A viable claim for negligence always requires proof that a defendant was required to conform his or her conduct to a specific standard of care and failed to do so. In a negligence action, a plaintiff always bears the burden of presenting evidence that “establishes the applicable standard of care, demonstrates that this standard has been violated, and develops a causal relationship between the violation and the harm complained of.” Morrison v. MacNamara,
407 A.2d 555, 560–61 (D.C. 1979) (citations omitted).