Banks v. Inspired Teaching School
243 F. Supp. 3d 1
| D.D.C. | 2017Background
- On September 17, 2015, plaintiff Louis A. Banks alleges school staff at Inspired Teaching School locked his son D.B. in a psychologist’s room, compelled testing, and that emergency services and police were called; the events led to medical treatment for D.B. and a police report describing abnormal behavior and threats of self-harm.
- Banks sued multiple defendants (Inspired Teaching School staff, Catholic Charities employees, D.C., and D.C. Child and Family Services Agency) in D.C. Superior Court asserting § 1983 constitutional claims and state torts (defamation, false light, false imprisonment), seeking $100 million; Superior Court dismissed the amended complaint with prejudice for failure to state a claim.
- Banks filed the present federal action reasserting the same constitutional and tort claims arising from the September 17 events against largely the same defendants.
- Defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), arguing the federal suit is barred by res judicata (claim preclusion) because the Superior Court judgment was final on the merits and involved the same parties and factual nucleus.
- The District Court reviewed the pleadings, took judicial notice of the Superior Court dismissal, and concluded all four elements of res judicata were satisfied, warranting dismissal of the federal complaint.
- The Court also denied the plaintiffs’ other pending motions and any requested discovery as moot in light of the dismissal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether claims are barred by res judicata | Banks maintains his claims recap the September 17 events and contest prior rulings as part of a broader conspiracy or judicial bias | Prior Superior Court suit involved same facts, parties, and resulted in final judgment on the merits; thus claim preclusion applies | Court: res judicata bars the federal suit; dismissal granted |
| Whether the amended complaint states a claim under Rule 12(b)(6) | Complaints allege constitutional violations and torts tied to the incident; seeks damages and relief | Because claims are precluded by prior dismissal, they fail as a matter of law | Court: dismissal for failure to state a claim (res judicata grounds) |
| Proper scope of judicial notice and consideration of Superior Court records | Banks disputes the prior ruling and labels it biased/conspiratorial | Defendants rely on Superior Court docket, amended complaint, and dismissal order as judicially noticeable records | Court considered Superior Court records and treated that judgment as final for res judicata purposes |
| Requests for discovery and other pending motions | Banks sought discovery and to reopen/reinstate matters | Defendants opposed; argued litigation is over on res judicata grounds | Court: denied plaintiffs’ pending motions and denied leave for discovery as moot |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading standard for Rule 12(b)(6) and Rule 8 notice pleading)
- Drake v. FAA, 291 F.3d 59 (D.C. Cir. 2002) (res judicata requires same claims, parties, final judgment, and competent court)
- Page v. United States, 729 F.2d 818 (D.C. Cir. 1984) (focus on common nucleus of facts for claim preclusion)
- Smalls v. United States, 471 F.3d 186 (D.C. Cir. 2006) (elements of claim preclusion stated)
- Haase v. Sessions, 835 F.2d 902 (D.C. Cir. 1987) (dismissal under Rule 12(b)(6) is a ruling on the merits for res judicata)
- Zellars v. United States, 578 F. Supp. 2d 1 (D.D.C. 2008) (application of res judicata in D.D.C.)