Justia U.S. D.C. Circuit Court of Appeals Opinion Summaries

Plaintiffs, the Libertarian Party's presidential and vice presidential candidates in the 2012 elections, filed suit claiming that they were excluded pursuant to an agreement between the Obama for America and Romney for President campaigns. Plaintiffs alleged that the parties' agreement reflected in a memorandum of understanding (MOU) stipulated to three presidential debates and one vice presidential debate, and designated dates, locations, moderators, and topics. Plaintiffs challenged the MOU as an unlawful agreement to monopolize and restrain competition in violation of sections 1 and 2 of the Sherman Act, 15 U.S.C. 1–2. The DC Circuit affirmed the district court's dismissal of the case. The court held that the doctrine of constitutional avoidance permitted the court to resolve this case on alternative grounds, based on antitrust standing. The court explained that the injuries plaintiffs claim were simply not those contemplated by the antitrust laws. Furthermore, plaintiffs failed to allege a clear legal claim, let alone identified a cognizable injury, in regard to their First Amendment claim. View "Johnson v. Commission on Presidential Debates" on Justia Law

Plaintiff, an African-American, filed suit against DHS, alleging that the Department's decision to give a promotion for which he was qualified to a Caucasian female employee just four weeks after he had complained of race and age discrimination was unlawful retaliation. The DC Circuit reversed the district court's dismissal of his retaliation claim for failure to exhaust remedies, holding that plaintiff expressly raised the non-promotion retaliation claim in his equal employment opportunity complaint. The record at this early procedural juncture showed that plaintiff came forth with sufficient factual allegations and inferences to require, at a minimum, that he be afforded discovery before summary judgment proceedings. Because the record contained a number of plausible factual disputes pertaining to plaintiff's claims of retaliation that could not be resolved on a motion for summary judgment, the court remanded those claims to the district court for further proceedings. View "Coleman v. Duke" on Justia Law

Plaintiff filed suit alleging claims that employees of Cities Restaurant and Lounge, and the Metropolitan Police Department officers they summoned, reacted overly harshly when she raised a question about her bill and temporarily left the restaurant. The DC Circuit affirmed the dismissal of the intentional and negligent infliction of emotional distress claims and the negligence claims against Officer Lee and the District of Columbia; affirmed the grant of summary judgment to Defendant Duru on all claims against him; and vacated the judgment on all remaining claims and remanded for further proceedings. The court held that allegations of the complaint sufficiently made out claims under 42 U.S.C. 1983 for false arrest and excessive force, as well as common law assault, false arrest, and false imprisonment against Officer Lee. Finally, the evidence was sufficient to create material factual disputes on the common law battery claim against Officer Lee, and the defamation, negligence, and conversion claims against Cities. View "Hall v. District of Columbia" on Justia Law

Plaintiff filed suit against the Department, alleging unlawful race and national origin discrimination under Title VII, 42 U.S.C. 2000e et seq. The DC Circuit subsequently decided sua sponte to reconsider the case and vacate its prior opinion. The court held that nothing in its Title VII precedent on lateral transfers would bar plaintiff from proceeding to trial and that he had otherwise proffered sufficient evidentiary support to show summary judgment was inappropriate. Accordingly, the court reversed and remanded for further proceedings. View "Ortiz-Diaz v. HUD" on Justia Law

Plaintiff filed suit against his employer, DHS, alleging race discrimination, retaliation, and a hostile work environment. The district court dismissed the case for failure to exhaust his administrative remedies. The DC Circuit held that attachments to plaintiff's administrative complaint adequately identified his claims alleging a discriminatory performance review and a later suspension. Therefore, these two claims were exhausted and the court reversed the district court's judgment in part. View "Crawford v. Duke" on Justia Law

After USCIS discovered that an employee had illegally issued nearly 200 certificates of naturalization to individuals who had not satisfied the requirements to become U.S. citizens, the government canceled certificates of naturalization to individuals, including plaintiffs here, without seeking a court order. The State Department then administratively revoked or refused to renew their passports. The D.C. Circuit affirmed the dismissal of plaintiffs' claims that the government's revocations of their certificates of naturalization and their passports violated the Immigration and Nationality Act and due process because they took place through administrative rather than judicial process; affirmed the dismissal of their claims of ethnicity or national origin discrimination; and reversed insofar as the district court held that any plaintiff was barred by failure to exhaust administrative remedies from challenging under the Administrative Procedure Act the government's failure to afford plaintiffs the review the law requires, and pursuing 8 U.S.C. 1503 claims in the correct venues. Accordingly, the court remanded in part. View "Xia v. Tillerson" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 against the District, alleging both procedural and substantive due process claims after he was sentenced to three consecutive weekends in the D.C. jail for a marijuana possession conviction in 2011 and remained in the jail for two years so that he could complete a prior sentence. The D.C. Superior Court denied his petition for habeas relief in 2012 and when plaintiff appealed, the D.C. Court of Appeals failed to act for another year and a half. The D.C. Circuit held that the Superior Court's 2012 decision lacked the preclusive effect the district court perceived. In this case, because plaintiff was unable to obtain a decision on his habeas appeal once he was no longer in custody, and because section 1983 claims cannot be joined in a habeas proceeding, the Superior Court's unreviewed bench ruling was not the result of a full and fair opportunity to litigate. On the merits, the court held that plaintiff's complaint stated a legally actionable procedural due process claim where his liberty interest sufficed to require that he be afforded some kind of process before he was locked up again. In regard to the substantive due process claim, the district court erred in dismissing that claim based on material beyond the complaint, and not incorporated by reference in it, without converting the motion to dismiss into one for summary judgment as contemplated by Federal Rules of Civil Procedure 12(d) and 56. Accordingly, the court vacated and remanded. View "Hurd v. District of Columbia" on Justia Law

Plaintiffs filed suit challenging D.C. Code provisions directing the District's police chief to promulgate regulations limiting licenses for the concealed carry of handguns (the only sort of carrying the Code allows) to those showing a good reason to fear injury to their person or property or any other proper reason for carrying a pistol (the "good-reason" law). The D.C. Circuit held that, at the core of the Second Amendment lies the right of responsible citizens to carry firearms for personal self-defense beyond the home, subject to longstanding restrictions. These traditional limits include, for instance, licensing requirements, but not bans on carrying in urban areas like D.C. or bans on carrying absent a special need for self-defense. In this case, the District's good-reason law is necessarily a total ban on most D.C. residents' right to carry a gun in the face of ordinary self-defense needs, where these residents are no more dangerous with a gun than the next law-abiding citizen. Therefore, the court could strike down the law apart from any particular balancing test. The court vacated the district courts' orders and remanded with instructions to enter permanent injunctions against enforcement of the good-reason law. View "Wrenn v. District of Columbia" on Justia Law

Appellant appealed the district court's dismissal of his habeas petition as time-barred, seeking a certificate of appealability (COA) from the DC Circuit. Because the petition was plainly time-barred and no jurist of reason could take issue with the procedural ruling by the district court, the court denied his request for a COA without having to reach his constitutional claim. View "Blount v. United States" on Justia Law

After her move to Treasury was blocked and her contract work with Fannie Mae was terminated, plaintiff filed suit alleging claims under District of Columbia law and, in the alternative, under Bivens. The DC Circuit affirmed the dismissal of the Bivens claim because the conservatorship over Fannie Mae did not create the type of permanent government control that is required under Lebron v. National Railroad Passenger Corp., 513 U.S. 374; affirmed summary judgment on her wrongful termination claim and rejected her request to recognize a public policy exception to the at-will doctrine based on the Emergency Economic Stabilization Act of 2008; affirmed summary judgment on her tortious interference with prospective contractual relations claim because she failed to demonstrate a genuine issue of material fact as to any valid business expectancy; affirmed summary judgment on the conspiracy claim because she failed to establish a cognizable underlying tort; and rejected her two discovery challenges. View "Herron v. Fannie Mae" on Justia Law