EDWARDS, Senior Circuit Judge. Judith C. Briggs filed a wrongful death and survival action seeking to recover damages from the Washington Metropolitan Area Transit Authority ("WMATA" or "Metro"), the District of Columbia ("District"), the Washington Convention Center Authority ("Authority"), Clark Construction Company ("Clark"), and Sherman R. Smoot Company ("Smoot") after an unknown assailant murdered her son near the top of the escalators at a Metro station in Washington, D.C. Under D.C. law, a plaintiff alleging negligence "`has the burden of proving . . . the applicable standard of care, a deviation from that standard by the defendant, and a causal relationship between the deviation and the . . . injury.'" Varner v. District of Columbia, 891 A.2d 260, 265 (D.C. 2006) (quoting District of Columbia v. Wilson, 721 A.2d 591, 597 (D.C. 1998)); accord Butera v. District of Columbia, 235 F.3d 637, 659 (D.C. Cir.2001). "Where an injury is caused by the intervening criminal act of a third party, . . . liability depends upon a more heightened showing of foreseeability than would be required if the act were merely negligent." District of Columbia v. Beretta, U.S.A., Corp., 872 A.2d 633, 641 (D.C. 2005) (en banc) (internal quotation marks omitted).

Under District of Columbia law, the plaintiff in a negligence action bears the burden of establishing three elements: “an applicable standard of care, a deviation from that standard by the defendant, and injury resulting from that deviation.” Scott v. Dist. of Columbia, 101 F.3d 748, 757 (D.C.Cir.1996); see also Varner v. Dist. of Columbia, 891 A.2d 260, 265 (D.C.2006); Allison v. Howard Univ., 209 F.Supp.2d 55, 61–62 (D.D.C.2002) (citing Hill v. Metro. African Methodist Episcopal Church, 779 A.2d 906, 908 (D.C.2001)). A. Plaintiff Failed to Establish a Standard of Care through Expert Testimony

Under District of Columbia law, a plaintiff seeking to prove her case through direct evidence of negligence has the burden of establishing three elements: (1) “the applicable standard of care”; (2) “a deviation from that standard by the defendant”; and (3) “a causal relationship” between the deviation and the injury she suffered. Varner v. District of Columbia, 891 A.2d 260, 265 (D.C.2006). To prove her case on this theory, Robinson argued that WMATA's check-your-mirror and “start gradually, stop smoothly” SOPs constituted applicable standards of care; that Bumpass deviated from those standards; and that her injury was the consequence of those deviations.

(citations omitted); see Varner v. D.C., 891 A.2d 260, 270 (D.C. 2006). That would be an independent reason to grant summary judgment to Defendants.

As such, "[i]n an action for negligence, the plaintiff has the burden of proving by a preponderance of the evidence the applicable standard of care, a deviation from that standard by the defendant, and a causal relationship between the deviation and the plaintiff's injury." Varner v. District of Columbia, 891 A.2d 260, 265 (D.C. 2006). The parties do not dispute that Mr. Frazza was lawfully on the White House grounds at the time of his injury, or that under District of Columbia law, "there is only one standard of care for persons lawfully upon [a] landowner's or land occupier's property, and that is reasonable care under the circumstances."

Night & Day Mgmt., LLC v. Butler , 101 A.3d 1033, 1038 (D.C. 2014) (quoting D.C. Hous. Auth. v. Pinkney , 970 A.2d 854, 866 (D.C. 2009) ). D.C. courts often require expert testimony to prove the standard of care. See Varner v. District of Columbia , 891 A.2d 260, 267–68 (D.C. 2006) (collecting cases). Where the subject of the alleged breach is "so distinctly related to some science, profession, or occupation as to be beyond the ken of the average lay juror," the plaintiff must produce expert testimony.

Where "the defendant is alleged to have failed to protect the plaintiff from harm, the expert must clearly articulate and reference a standard of care by which the defendant's actions can be measured." Varner v. District of Columbia , 891 A.2d 260, 269 (D.C. 2006) (internal quotation marks omitted). Specifically, "the expert must clearly relate the standard of care to the practices in fact generally followed by other comparable ... facilities or to some standard nationally recognized by such units."

Where “the defendant is alleged to have failed to protect the plaintiff from harm, the expert must ‘clearly articulate and reference a standard of care by which the defendant's actions can be measured.’ ” Varner v. District of Columbia, 891 A.2d 260, 269 (D.C.2006) (citation and emphasis omitted). Moreover, “[a]n expert may not rely upon a general duty of care to establish an objective standard requiring specific conduct.”

Restatement (Second) of Torts § 283 (1965). In cases involving crowd control and public safety, courts have often concluded that expert testimony is needed to define the requisite standard of care. Edwards v. Okie Dokie, Inc., 473 F.Supp.2d 31, 45 (D.D.C.2007); Varner v. District of Columbia, 891 A.2d 260, 265 (D.C.2006) (quoting District of Columbia v. Wilson, 721 A.2d 591, 597 (D.C.1998)); but see Godfrey v. Iverson, 559 F.3d 569, 572 (D.C.Cir.2009) (emphasizing that expert testimony is not always required). And if expert testimony is necessary to establish the relevant standard of care, a plaintiff's failure to name an expert may be fatal to her claim.

In September 2000, Eric Plunkett was murdered by Joseph Mesa — although the murderer's identity would go undiscovered for over four months, during which time he killed another Gallaudet University student. See Varner v. District of Columbia, 891 A.2d 260, 264 (D.C. 2006) (summarizing facts surrounding the deaths of Gallaudet University students Eric Plunkett and Andrew Varner). On Thursday, September 29, 2000, around 9 p.m., students entered Plunkett's dorm room to check up on him after not having seen or heard from him all day. To their horror, they discovered his lifeless body lying in a blood-splattered room. Plunkett's body was transported to D.C. General Hospital where the medical examiner pronounced him dead and ruled the cause of death as homicide. The autopsy report concluded that Plunkett died from "Blunt Force Trauma and a Broken Neck."