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

Plaintiff filed suit against the Department, alleging that her new supervisor retaliated against her for earlier discrimination complaints. The district court granted summary judgment in favor of the Department. The supervisor justified plaintiff's low performance ratings on the ground that plaintiff, a managerial employee, failed adequately to supervise satellite offices and external contractors. Further, the supervisor attested that plaintiff was never excluded from meetings and that plaintiff could have attended meetings, but never did. The court concluded that the proffered facts could not, if presented a trial, support a jury verdict that retaliation was the supervisor's real motive for the actions of which plaintiff complains. Accordingly, the court affirmed the district court's judgment. View "Allen v. Johnson" on Justia Law

Plaintiff filed suit against the Department, alleging that her new supervisor retaliated against her for earlier discrimination complaints. The district court granted summary judgment in favor of the Department. The supervisor justified plaintiff's low performance ratings on the ground that plaintiff, a managerial employee, failed adequately to supervise satellite offices and external contractors. Further, the supervisor attested that plaintiff was never excluded from meetings and that plaintiff could have attended meetings, but never did. The court concluded that the proffered facts could not, if presented a trial, support a jury verdict that retaliation was the supervisor's real motive for the actions of which plaintiff complains. Accordingly, the court affirmed the district court's judgment. View "Allen v. Johnson" on Justia Law

Plaintiff is the mother of Karl Grimes, a juvenile who was allegedly beaten to death at a detention facility. Plaintiff claimed that the District showed deliberate indifference to, and reckless disregard for, her son’s safety, and that the District was negligent in hiring, training, and supervising its employees at the detention center in violation of District of Columbia tort law, the Eighth Amendment, and 42 U.S.C. 1983. The district court granted the government’s motion for summary judgment, and denied as moot plaintiff’s cross-motion to strike the summary judgment motion and to disqualify the Attorney General of the District of Columbia based on an asserted conflict of interest. The court concluded that the district court should resolve a motion to disqualify counsel before it turns to the merits of any dispositive motion because a claim of counsel’s conflict of interest calls into question the integrity of the process in which the allegedly conflicted counsel participates. Therefore, the court concluded that the district court erred in the sequence in which it rendered its decisions. Accordingly, the court vacated the district court's grant of summary judgment and its denial of the motion to disqualify, and remanded for further proceedings. View "Grimes v. District of Columbia" on Justia Law

Plaintiffs, Medicaid recipients who unsuccessfully sought coverage for prescription drugs, filed suit contending that the District and its officials unlawfully failed to afford them notice of their entitlement to a hearing before denying their prescription drug claims. The court affirmed the district court's dismissal of plaintiffs' claims under Title XIX of the Social Security Act, 42 U.S.C. 1396 et seq., and rejected plaintiffs’ argument that Title XIX’s notice regulations are triggered whenever there has been a denial of a claim for prescription drug coverage at the point-of-sale. However, the court reversed the district court's dismissal of the due process claims because the prescription drug coverage sought by plaintiffs qualifies as a property interest protected by the Fifth Amendment; plaintiffs adequately alleged that Xerox, a private company, determined their eligibility for benefits while acting as an agent of the District; and the court remanded the case to permit the district court to conduct an inquiry in the first instance into what process is due. The court also remanded to the district court to reconsider its jurisdiction over the D.C. -law claims in light of the court's partial reversal. View "NB v. District of Columbia" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 alleging that a police officer violated her Fourth Amendment right when, during her husband’s traffic stop and arrest, the officer ordered her to get out of the car and put her hands on the hood. Given the circumstances of plaintiff’s alleged seizure, nothing in her brief shows that existing precedent has placed her Fourth Amendment right beyond debate. The court affirmed the district court's grant of the officer's motion for judgment on the pleadings, concluding that the factual allegations in the complaint do not plausibly suggest that the officer violated plaintiff's clearly established Fourth Amendment right. View "Fox v. Government of DC" on Justia Law

After the court held, in 2005, that a Postal Service regulation was unconstitutional based on the regulation's ban on signature collection on perimeter sidewalks, the Postal Service amended its regulation to correct the constitutional defects. The plaintiff nonprofit organizations subsequently applied for attorney’s fees under the Equal Access to Justice Act, 28 U.S.C. 2412(d)(1)(A). The district court denied the fee application on the ground that plaintiffs were not prevailing parties under the Act. However, the court concluded that its 2005 decision effectuated a court-ordered change in the legal relationship of the parties. The court agreed with plaintiffs that they obtained a favorable, court-ordered change and plaintiffs easily satisfy the remaining two prongs of the “prevailing party” test: They achieved a judgment “in favor of the party seeking the fees” and a judicial pronouncement “accompanied by judicial relief.” Accordingly, the court reversed and remanded for further proceedings. View "Initiative and Referendum Inst. v. USPS" on Justia Law

Plaintiff, who suffers from Multiple Sclerosis (MS), filed suit against her former employer, TEFCU, for wrongful termination in violation of the Americans with Disabilities Act of 1990 (ADA), 42 U.S.C. 12101 et seq.; the District of Columbia Human Rights Act (DCHRA), D.C. CODE 2-1401.01 et seq.; and Section 510 of the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1140. Plaintiff alleged that the cost of treating her MS was causing the monthly healthcare insurance premium to rise and that TEFCU dismissed her to reduce its health care costs. TEFCU claimed that plaintiff's termination was due to her poor performance as an employee. The district court granted TEFCU's motion for summary judgment and plaintiff appealed. The court concluded that no reasonable jury could infer that TEFCU dismissed plaintiff because of the costs associated with insuring her. The court also concluded that the district court did not abuse its discretion in denying plaintiff's motion for sanctions where plaintiff provides no citation to authority or to the record demonstrating that the district court's denial was premised upon an erroneous conclusion of law, an erroneous factual finding, or that it was otherwise unreasonable. Accordingly, the court affirmed the judgment. View "Giles v. Transit Emp. Fed. Credit Union" on Justia Law

Plaintiff filed suit against the District, alleging a violation of the Individuals with Disabilities Education Act (IDEA), 20 U.S.C.1400 et seq. After plaintiff prevailed, the district court awarded her $62,225 in attorneys' fees and costs for approximately one hundred hours of work. On appeal, the District argued that the district court abused its discretion when it adopted plaintiff's proposed fee matrix. The court concluded that the district court abused its discretion in relieving plaintiff of her burden of demonstrating the reasonableness of the rates. In this case, plaintiff's proposed fee matrix set the prevailing market rate for her lawyer’s services well beyond the next highest hourly rate used by district courts in IDEA litigation. Accordingly, the court vacated the fee award and remanded. View "Eley v. District of Columbia" on Justia Law

Plaintiffs, investigators with the Department, filed suit against the District under the D.C. Whistleblower Protection Act, D.C. Code 1-615.51 et seq., alleging that they were unlawfully reassigned to a less desirable position in retaliation for disclosures they allegedly made accusing their superiors of gross mismanagement and racial discrimination in the workplace. The unrebutted explanation the District has offered is that the Department reassigned plaintiffs because District prosecutors refused to work with either of them and not because they had filed Equal Employment Opportunity complaints with the Department alleging racial discrimination. Because plaintiffs failed to rebut this explanation, the court held that they have failed to demonstrate a genuine issue of disputed fact sufficient to survive summary judgment on their claim. Accordingly, the court affirmed the district court's grant of summary judgment to the District. View "Bowyer v. District of Columbia" on Justia Law

Plaintiff filed suit against three officials of the AO, in their official capacities, claiming that their refusal to consider her job application violated her right to travel protected by the Constitution of the United States. The district court granted summary judgment to defendants. The court held that the AO’s decision to limit its applicant pool to employees of the federal judiciary and individuals who lived in the Washington metropolitan area did not violate plaintiff’s right to travel, whether that right is considered under the Privileges and Immunities Clause of Article IV because it does not constrain the powers of the federal government; the equal protection component of the Due Process Clause of the Fifth Amendment because the geographical limitation does not implicate the component of plaintiff's right to travel; or the essential structure of the Constitution. Further, the court concluded that the district court did not abuse its discretion by denying plaintiff’s request for discovery before entering summary judgment for defendants. View "Pollack v. Duff" on Justia Law