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

Plaintiff filed suit against defendants, alleging that the termination of his employment violated the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621 et seq. The district court granted summary judgment in favor of defendants. Plaintiff introduced evidence of two statements made by the person who effected his termination, both of which were indicative of a discriminatory motive. The court reversed and remanded because those statements, if proven to have been made, would permit a reasonable factfinder to conclude that age-based discrimination led to plaintiff's termination.View "Wilson v. Cox, et al." on Justia Law

Plaintiffs filed a putative class action alleging that aerial herbicide spraying of illegal coca crops had drifted across the border from Colombia and that planes themselves had actually crossed the border and sprayed in Ecuador. Plaintiffs asserted a wide variety of tort claims for alleged injuries to health, property, and financial interests. The court agreed with the district court that the Ecuadorian provinces lacked Article III standing; the court rejected the challenge brought by the 163 plaintiffs who were dismissed for failure to provide complete responses to the court-ordered questionnaires; because District of Columbia law requires expert testimony where the parties offer competing causal explanations for an injury that turns on scientific information, the district court appropriately dismissed individual plaintiffs' claims for crop damages; because expert testimony was not necessary to prove plaintiffs' claims for battery, nuisance, and intentional infliction of emotional distress, the district court erred in dismissing these claims; and because expert testimony is necessary to determine whether plaintiffs were actually in the zone of physical danger, the court affirmed the district court's dismissal of the negligent infliction of emotional distress claims. Accordingly, the court affirmed in part, reversed in part, and remanded for further consideration., battery, nuisance, iemdView "Arias, et al. v. Dyncorp, et al." on Justia Law

After plaintiff was discharged by the Department of Corrections, he filed suit against the District and two officials, alleging violations of his rights under the District's whistleblower statute, D.C. Code 1-615.53, and of his liberty interests under the Fifth Amendment. The court affirmed the district court's grant of summary judgment on the claims under the whistleblower act where plaintiff was terminated for the misconduct that occurred in March 2005, not January 2006, where he struck a handcuffed inmate. The court also affirmed summary judgment on the Fifth Amendment claim where any deprivation of liberty by stigmatizing was not without due process. Accordingly, the court affirmed the judgment of the district court.View "McCormick, Jr. v. D.C., et al." on Justia Law

Plaintiffs, prisoners who violated D.C. criminal laws before March 3, 1985, filed suit contending that the Parole Commission contravened the Ex Post Facto Clause by retroactively applying parole guidelines that it issued in 2000, instead of the guidelines in place at the time of their offenses. The court reversed the district court's dismissal of the complaint for failure to state a claim because the court concluded that plaintiffs have plausibly alleged that the application of the 2000 guidelines creates a "significant risk of prolonging [their] incarceration." The court remanded for further proceedings. View "Daniel, et al. v. Fulwood, Jr., et al." on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983, alleging that the District bore responsibility for the Board's unconstitutional parole revocation decision after the Board determined that plaintiff's parole was based primarily on unreliable multiple-hearsay testimony. The district court found the District liable and a jury awarded defendant damages. The District appealed. The court concluded that the Rooker-Feldman doctrine did not bar the district court from having jurisdiction over plaintiff's claim; the court held that the District is not liable under section 1983 for the Board's decision and the District was entitled to summary judgment on the question of its liability; and, therefore, the court vacated and remanded. View "Singletary v. District of Columbia" on Justia Law

Plaintiffs, former officers who had been medically disqualified from serving as federal court security officers, filed suit against the Marshals Service alleging that the procedures culminating in their dismissals failed to satisfy the Due Process Clause, and that their dismissals had been motivated by discrimination in violation of the Rehabilitation Act, 29 U.S.C. 701 et seq. The court affirmed the district court's grant of summary judgment for defendants on the Due Process Clause claims where there was no need to give an officer an oral hearing where an officer was given the opportunity to supply additional medical information responding to specific concerns of the physician charged with making the final decision; the court affirmed the district court's grant of judgment on the pleadings on the Rehabilitation Act claims where plaintiffs failed to exhaust their claims against the government; but the court reversed the district court's denial of leave to amend to add the discrimination claims where the district court abused its discretion when it denied leave to include the claims of twelve new plaintiffs in the fifth amended complaint. The court remanded for further proceedings. View "United Government Security, et al. v. United States Marshals, et al." on Justia Law

The District and two police officers appealed the district court's liability determinations resulting from the grant of partial summary judgment against them. The district court granted partial summary judgment in plaintiffs' favor because no reasonable officer in their shoes could have found probable cause to arrest any of the plaintiffs. The officers arrested everyone present at a party for unlawful entry because the host of the party had not finalized any rental agreement and so lacked the right to authorize the party. The court concluded that the officers lacked probable cause for the arrest because it was undisputed at the time that the arresting officers knew plaintiffs had been invited to the house by a woman that they reasonably believed to be its lawful occupant. The court also concluded that the officers lacked probable cause to arrest for disorderly conduct because the evidence failed to show any disturbance of sufficient magnitude to violate local law. Accordingly, the court affirmed the district court's grant of summary judgment to plaintiffs on the ground that the arrests violated their clearly established Fourth Amendment rights and District of Columbia law against false arrest. The court also affirmed the district court's holding that the District was liable for negligent supervision because the supervising police sergeant at the scene also overstepped clear law in directing the arrests. View "Wesby, et al. v. DC, et al." on Justia Law

This case stemmed from efforts by various environmental and historical preservation organizations to obtain the Blair Mountain Battlefield's listing in the National Register of Historic Places. After the Battlefield was briefly included in the Register and then removed, the organizations filed suit challenging the Battlefield's removal from the Register. The district court granted summary judgment against the organizations based on their lack of standing. The court concluded, however, that the organizations have adequately demonstrated injury in fact, causation, and redressability. Accordingly, the court reversed and remanded for further proceedings. View "Sierra Club, et al. v. Jewell, et al." on Justia Law

Plaintiff filed suit against her employer, the Department of Agriculture, after it denied her request for a flexible work schedule based on her depression. Plaintiff sought substantial flexibility in her working hours ("maxiflex" schedule) under the Rehabilitation Act of 1973, 29 U.S.C. 701 et seq., as an accommodation for her disability. The district court granted summary judgment to the Department, concluding that the maxiflex work schedule is an unreasonable request. The court also rejected defendant's retaliation claims. The court concluded, however, that nothing in the Rehabilitation Act establishes, as a matter of law, that a maxiflex work schedule is unreasonable. Accordingly, the court reversed the entry of summary judgment on the accommodation claim; reversed the entry of summary judgment on plaintiff's claim that revoking her permission to work late was in retaliation for requesting accommodations; and remanded those claims for further proceedings. The court affirmed the remainder of the district court's decision. View "Solomon v. Vilsack" on Justia Law

Plaintiff, employed as an attorney advisor for the BVA, filed suit against the Secretary of the VA, claiming that the BVA had violated her rights under the Rehabilitation Act of 1973, 29 U.S.C. 701 et seq., by failing to accommodate her disability. Plaintiff also claimed that she was constructively discharged because the failure to accommodate her disability left her no choice but to resign. In regards to the failure to accommodate claim, no reasonable jury could find that plaintiff's accommodation request was denied in light of the BVA's continuing good-faith dialogue with plaintiff to determine an appropriate accommodation, which dialogue was cut short by plaintiff's sudden resignation. Consequently, plaintiff's constructive discharge claim also failed. Accordingly, the court affirmed the district court's grant of summary judgment to the Secretary on both claims. View "Ward v. McDonald" on Justia Law