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

Plaintiff sued defendant, alleging that defendant had unlawfully discriminated against her in violation of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq. Plaintiff, a medical student who was diagnosed with dyslexia and a mild processing-speed disorder, contended on remand that the district court erred by failing to apply the 2008 amendments to the ADA and in relying on her prior academic achievement in assessing whether she suffered from a disability under the ADA. The court held that because plaintiff failed to show legal or clear factual error by the district court, the judgment was affirmed. View "Singh v. GW Univ. School of Medicine, et al." on Justia Law

The District of Columbia appealed the denial of its motion to vacate a preliminary injunction pursuant to Rule 60(b)(5) of the Federal Rules of Civil Procedure. The injunction was issued in 1995 in response to a class action complaint alleging that the District of Columbia was violating the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq., by failing to timely pay private providers of special education services and thereby jeopardizing students' special education placements. The district court denied the motion on two grounds: (1) dissolving the injunction and subsequent payment orders "would be disruptive to the status quo" and "counter-productive to the goal" of settling the case "in short order," and (2) the District of Columbia had "overstated both the relevance and the significance" of the Supreme Court's recent decision in Horne v. Flores. The court held that the district court failed to address changed circumstances, as Flores instructed, and reversed and remanded the case to the district court to determine whether, in view of changed circumstances, the District of Columbia's Rule 60(b)(5) motion should be granted. View "Petties, et al. v. District of Columbia, et al." on Justia Law

After injuring her back in a car accident, plaintiff filed for and received long-term disability benefits from the insurance plan sponsored by her employer. Plaintiff brought suit pursuant to the Employee Retirement Income Security Act of 1974 (ERISA), 42 U.S. C. 29 U.S.C. 1001 et seq., against her employer and the administrators and underwriters of her employer-sponsored long-term benefit disability insurance policy after the claims administrator of that plan determined that she no longer qualified for benefits. At issue was whether the district court properly granted defendants' motion for summary judgment, finding no violation of law. The court held that because defendants acted reasonably, the court concluded that defendants' termination of plaintiff's benefits complied with federal law. The court found none of plaintiff's procedural claims persuasive and held that the district court did not err when it held that defendants did not violate plaintiff's right to a full and fair review of her adverse eligibility determination. The court also rejected plaintiff's argument that the district court violated local rule 7(h) where plaintiff failed to make this argument before the district court. Accordingly, the court affirmed the judgment of the district court.

The District of Columbia filed this suit to recover its attorneys' fees from a lawyer who brought an administrative complaint against the District on behalf of a student with special educational needs under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400(d)(1)(A). At issue was whether the District was a "prevailing party" under the IDEA in this suit. The court held that the facts in this case followed closely in the wake of the court's precedent in District of Columbia v. Straus where that court held that the district was not a "prevailing party" where its own change of position was what had mooted the dispute, causing the case to be dismissed. Therefore, the court held that the District, in this case, was not a "prevailing party" where the District of Columbia Public Schools (DCPS) authorized an independent comprehensive psychological evaluation for the student, which mooted the only issue before the hearing officer. Accordingly, the district court's grant of summary judgment ordering the lawyer to pay attorneys' fees was reversed.