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

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

Plaintiffs, individual government contractors, challenged 52 U.S.C. 30119(a)(1) as violating their First Amendment and equal protection rights. 52 U.S.C. 30119(a)(1) barred individuals and firms from making federal campaign contributions while they negotiate or perform federal contracts. The court rejected plaintiffs' challenge because the concerns that spurred the original bar remain as important today as when the statute was enacted, and because the statute is closely drawn to avoid unnecessary abridgment of associational freedoms. The court stated that there is no dispute regarding the legitimacy or importance of the interests that support the contractor contribution ban. The ban is not only supported by the compelling interest in protecting against quid pro quo corruption and its appearance, it is also supported by the obviously important interest in protecting merit-based public administration commonly at issue in cases involving limits on partisan activities by government employees. Further, the statute employs means closely drawn to avoid unnecessary abridgement of associational freedoms, and does not deprive the plaintiffs of equal protection of the laws View "Wagner v. Federal Election Comm'n" on Justia Law

Plaintiff, a lawyer for the PBGC, filed suit claiming that, in retaliation for her Title VII activities, the PBGC made her work environment a hostile one. Both of plaintiff's complaints have been consolidated on appeal. The court concluded that the incidents the PBGC failed to remediate would not themselves constitute a retaliatory hostile work environment, and that several instances of rude emails, name-calling, lost tempers and unprofessional behavior do not amount to a retaliatory hostile work environment. Accordingly, the court affirmed the dismissal of her two complaints. View "Baird v. Gotbaum" on Justia Law

Plaintiff, a federal prison inmate, filed suit alleging that the BOP failed to adequately respond to his requests for records under the Freedom of Information Act (FOIA), 5 U.S.C. 500 et seq., and that several policies adopted by the BOP violate the Constitution. The district court granted summary judgment for the BOP on the FOIA claims and dismissed the constitutional claims. The court concluded that because it cannot determine whether the BOP conducted an adequate search based upon the declarations in the record, the judgment of the district court on the Code 408 FOIA claim is vacated and the court remanded for further proceedings. The court held that sovereign immunity does not bar plaintiff’s claims for declaratory and injunctive relief against the BOP and the individual defendants in their official capacities; plaintiff exhausted all the administrative remedies “available” to him with respect to his claim that defendants unlawfully retained interest earned on money held in inmates’ deposit accounts; the court affirmed the district court's dismissal of plaintiff's claim that the prices charged for commissary items and telephone calls are “too high;” the court vacated the district court’s order insofar as it dismisses plaintiff’s claim that Code 334 is unconstitutional and remanded for further proceedings; and the court affirmed as to the remaining claims. View "DeBrew v. Atwood" on Justia Law

Petitioner, a Guantanamo Bay detainee, raised two challenges to the constitutionality of the United States Court of Military Commission Review (CMCR). The court held that petitioner is not entitled to mandamus relief because this Court can consider his Appointments Clause and Commander-in-Chief Clause challenges on direct appeal, after the military commission renders a final judgment and the convening authority and the CMCR review it. Further, petitioner failed to demonstrate a “clear and indisputable” right to the writ. Therefore, the court denied petitioner's petition for writ of mandamus and prohibition. View "In re: Abd Al-Rahim Hussein Al-Nashir" on Justia Law

Plaintiff, employed by WASA for sixteen years, filed suit against WASA on numerous grounds, including violating Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., by retaliating against him for opposing racially discriminatory employment practices. The district court dismissed the complaint and plaintiff appealed. The court concluded that, because plaintiff's complaint alleged facts that, if shown, would be at least sufficient to state a prime facie case of retaliation - and perhaps enough to survive summary judgment - it necessarily alleged facts sufficient to render his claim plausible at the motion to dismiss stage. Accordingly, the court reversed the dismissal. View "Harris v. DC Water and Sewer Auth." on Justia Law

Plaintiff filed suit alleging that 18 U.S.C. 922(a)(9) and (b)(3) and implementing regulations are unconstitutional because the provisions, in effect, prohibit citizens not residing in any state from purchasing firearms. At issue was whether a citizen who permanently resides outside the United States has a right under the Second Amendment to purchase a firearm for self-defense while he is temporarily visiting this country. In this case, the court concluded that there are too many unanswered questions regarding plaintiff’s particular situation even though he seeks to mount an as applied challenge. Accordingly, the court vacated the district court's grant of summary judgment in favor of the United States and remanded for trial. View "Dearth v. Lynch" on Justia Law