What is the test for establishing that an injury sustained in a motor vehicle accident can be repeated?

In order to establish that an injury is capable of repetition, a plaintiff must make a " 'reasonable showing' of a 'sufficient likelihood' " that the injury will recur. Id. at 1339-40 (quoting City of Los Angeles v. Lyons, 461 U.S. 95, 109 (1983)). "The 'mere physical or theoretical possibility' of a challenged action again affecting a plaintiff is not sufficient." Id. (quoting Murphy v. Hunt, 455 U.S. 478, 482 (1982)). The plaintiff bears the burden of meeting this standard. Id. at 1343.