knowledge standard in District of Columbia

2024African Methodist Episcopal Church, 779 A.2d 906 , 908 n.1 (D.C. 2001) (quoting District of Columbia v. Hampton, 666 A.2d 30, 35-36 (D.C. 1995)). 11 juror.3 We find appellants’ argument unpersuasive because it conflates the knowledge gained from experience by a lay metro user with the knowledge required to establish a standard of care.

2001In District of Columbia v. Hampton, 666 A.2d 30, 35-36 (D.C.1995), we referred to the "general rule requiring expert testimony to prove the applicable standard of care,” noting that "over the last decade or so ... the requirement has been applied more broadly to a variety of situations” with numerous examples, and noting also "the substantially smaller number of cases falling within the common knowledge exception.” 2 .

2011See, e.g., Cowan, 922 So.2d at 566 (holding that the entire statute "contains an actual knowledge standard”); Suiter v. Epperson, 6 Neb.App. 83 , 571 N.W.2d 92, 104-05 (1997) (interpreting the "plain language” of the statute to prohibit " 'knowingly' permitting or authorizing” an unlicensed driver to operate a vehicle); City of Brook Park, 570 N.E.2d at 293 (finding that "knowingly” applied to both "authorize” and "permit”); Spencer v. Gamboa, 102 N.M. 692 , 699 P.2d 623, 624 (App.1985) ("The language 'authorized or knowingly permit’ means 'know or should have known.’ ”); People v. Shapiro, 4

2011See, e.g., Cowan, 922 So.2d at 566 (holding that the entire statute "contains an actual knowledge standard”); Suiter v. Epperson, 6 Neb.App. 83 , 571 N.W.2d 92, 104-05 (1997) (interpreting the "plain language” of the statute to prohibit " 'knowingly' permitting or authorizing” an unlicensed driver to operate a vehicle); City of Brook Park, 570 N.E.2d at 293 (finding that "knowingly” applied to both "authorize” and "permit”); Spencer v. Gamboa, 102 N.M. 692 , 699 P.2d 623, 624 (App.1985) ("The language 'authorized or knowingly permit’ means 'know or should have known.’ ”); People v. Shapiro, 4

2011See, e.g., Cowan, 922 So.2d at 566 (holding that the entire statute "contains an actual knowledge standard”); Suiter v. Epperson, 6 Neb.App. 83 , 571 N.W.2d 92, 104-05 (1997) (interpreting the "plain language” of the statute to prohibit " 'knowingly' permitting or authorizing” an unlicensed driver to operate a vehicle); City of Brook Park, 570 N.E.2d at 293 (finding that "knowingly” applied to both "authorize” and "permit”); Spencer v. Gamboa, 102 N.M. 692 , 699 P.2d 623, 624 (App.1985) ("The language 'authorized or knowingly permit’ means 'know or should have known.’ ”); People v. Shapiro, 4

2011See, e.g., Cowan, 922 So.2d at 566 (holding that the entire statute "contains an actual knowledge standard”); Suiter v. Epperson, 6 Neb.App. 83 , 571 N.W.2d 92, 104-05 (1997) (interpreting the "plain language” of the statute to prohibit " 'knowingly' permitting or authorizing” an unlicensed driver to operate a vehicle); City of Brook Park, 570 N.E.2d at 293 (finding that "knowingly” applied to both "authorize” and "permit”); Spencer v. Gamboa, 102 N.M. 692 , 699 P.2d 623, 624 (App.1985) ("The language 'authorized or knowingly permit’ means 'know or should have known.’ ”); People v. Shapiro, 4

2011See, e.g., Cowan, 922 So.2d at 566 (holding that the entire statute "contains an actual knowledge standard”); Suiter v. Epperson, 6 Neb.App. 83 , 571 N.W.2d 92, 104-05 (1997) (interpreting the "plain language” of the statute to prohibit " 'knowingly' permitting or authorizing” an unlicensed driver to operate a vehicle); City of Brook Park, 570 N.E.2d at 293 (finding that "knowingly” applied to both "authorize” and "permit”); Spencer v. Gamboa, 102 N.M. 692 , 699 P.2d 623, 624 (App.1985) ("The language 'authorized or knowingly permit’ means 'know or should have known.’ ”); People v. Shapiro, 4

2011See, e.g., Cowan, 922 So.2d at 566 (holding that the entire statute "contains an actual knowledge standard”); Suiter v. Epperson, 6 Neb.App. 83 , 571 N.W.2d 92, 104-05 (1997) (interpreting the "plain language” of the statute to prohibit " 'knowingly' permitting or authorizing” an unlicensed driver to operate a vehicle); City of Brook Park, 570 N.E.2d at 293 (finding that "knowingly” applied to both "authorize” and "permit”); Spencer v. Gamboa, 102 N.M. 692 , 699 P.2d 623, 624 (App.1985) ("The language 'authorized or knowingly permit’ means 'know or should have known.’ ”); People v. Shapiro, 4

2011See, e.g., Cowan, 922 So.2d at 566 (holding that the entire statute "contains an actual knowledge standard”); Suiter v. Epperson, 6 Neb.App. 83 , 571 N.W.2d 92, 104-05 (1997) (interpreting the "plain language” of the statute to prohibit " 'knowingly' permitting or authorizing” an unlicensed driver to operate a vehicle); City of Brook Park, 570 N.E.2d at 293 (finding that "knowingly” applied to both "authorize” and "permit”); Spencer v. Gamboa, 102 N.M. 692 , 699 P.2d 623, 624 (App.1985) ("The language 'authorized or knowingly permit’ means 'know or should have known.’ ”); People v. Shapiro, 4

2011See, e.g., Cowan, 922 So.2d at 566 (holding that the entire statute "contains an actual knowledge standard”); Suiter v. Epperson, 6 Neb.App. 83 , 571 N.W.2d 92, 104-05 (1997) (interpreting the "plain language” of the statute to prohibit " 'knowingly' permitting or authorizing” an unlicensed driver to operate a vehicle); City of Brook Park, 570 N.E.2d at 293 (finding that "knowingly” applied to both "authorize” and "permit”); Spencer v. Gamboa, 102 N.M. 692 , 699 P.2d 623, 624 (App.1985) ("The language 'authorized or knowingly permit’ means 'know or should have known.’ ”); People v. Shapiro, 4

2002American Mutual was decided in 1970, and, under M.A.P. v. Ryan, 285 A.2d 810, 312 (D.C.1971), no division of this court may overrule a decision that was rendered by the United States Court of Appeals for the District of Columbia Circuit prior to February 1, 1971.

1996See Womack v. United States, 350 A.2d 381, 384 (D.C.1976) (identifying the knowledge requirement); see also Pettibone v. United States, 148 U.S. 197, 206 , 13 S.Ct. 542, 546 , 37 L.Ed. 419 (1893) (requiring proof that the accused knew that the witness was a witness).

1996See Womack v. United States, 350 A.2d 381, 384 (D.C.1976) (identifying the knowledge requirement); see also Pettibone v. United States, 148 U.S. 197, 206 , 13 S.Ct. 542, 546 , 37 L.Ed. 419 (1893) (requiring proof that the accused knew that the witness was a witness).

1996See Womack v. United States, 350 A.2d 381, 384 (D.C.1976) (identifying the knowledge requirement); see also Pettibone v. United States, 148 U.S. 197, 206 , 13 S.Ct. 542, 546 , 37 L.Ed. 419 (1893) (requiring proof that the accused knew that the witness was a witness).

1991See Powell, 289 U.S.App.D.C. at -, 929 F.2d at 728 (for aiding and abetting conviction, "accomplice must have known to a practical certainty that the principal would be carrying a gun”); United States v. Morrow, 923 F.2d 427, 436 (6th Cir.1991) (to convict for aiding and abetting, jury had to find appellant “somehow knowingly advised, counseled, encouraged, or assisted [the principal] in carrying the gun in relation to the underlying crimes"); United States v. Hamblin, 911 F.2d 551, 558 (11th Cir.1990) (for aiding and abetting conviction, government had “burden of proving that [accomplice] sha

1991See Powell, 289 U.S.App.D.C. at -, 929 F.2d at 728 (for aiding and abetting conviction, "accomplice must have known to a practical certainty that the principal would be carrying a gun”); United States v. Morrow, 923 F.2d 427, 436 (6th Cir.1991) (to convict for aiding and abetting, jury had to find appellant “somehow knowingly advised, counseled, encouraged, or assisted [the principal] in carrying the gun in relation to the underlying crimes"); United States v. Hamblin, 911 F.2d 551, 558 (11th Cir.1990) (for aiding and abetting conviction, government had “burden of proving that [accomplice] sha

1991See Powell, 289 U.S.App.D.C. at -, 929 F.2d at 728 (for aiding and abetting conviction, "accomplice must have known to a practical certainty that the principal would be carrying a gun”); United States v. Morrow, 923 F.2d 427, 436 (6th Cir.1991) (to convict for aiding and abetting, jury had to find appellant “somehow knowingly advised, counseled, encouraged, or assisted [the principal] in carrying the gun in relation to the underlying crimes"); United States v. Hamblin, 911 F.2d 551, 558 (11th Cir.1990) (for aiding and abetting conviction, government had “burden of proving that [accomplice] sha

1979See Butler v. Frazee, supra, 211 U.S. at 465-66 , 29 S.Ct. 136 ; M.

1979See Butler v. Frazee, supra, 211 U.S. at 465-66 , 29 S.Ct. 136 ; M.