Barryman-Turner v. District of Columbia, 233 F. Supp. 3d 26

Karen Berryman‑Turner is a former D.C. corrections officer who received disability benefits for head injuries suffered in 1996; the District notified her of termination of benefits effective May 17, 2003, based on two independent medical examinations.
The termination notice informed her she could seek reconsideration (which would extend benefits during reconsideration) or appeal to an administrative law judge (ALJ) (which would not extend benefits); she appealed to an ALJ and benefits stopped on May 17, 2003; the ALJ upheld the termination on October 1, 2003.
Berryman‑Turner was a member of the certified class in Lightfoot, a prior class action challenging the District’s disability‑benefits termination procedures; Lightfoot dismissed several classwide constitutional claims and ultimately decertified the class.
After an earlier dismissal ruling by this Court (Barryman‑Turner v. District of Columbia, 115 F. Supp. 3d 126 (D.D.C. 2015)), Berryman‑Turner filed a seven‑count amended complaint asserting § 1983 due‑process claims, a D.C. law damages claim, and a claim for potential future damages.
The District moved to dismiss and for summary judgment, arguing res judicata, law‑of‑the‑case, lack of standing/ripeness, and that adequate process was provided; the Court granted dismissal or summary judgment on all counts.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Preclusion of constitutional claims (Counts 1,3,4,5)	Claims duplicate issues litigated in Lightfoot; she remained a class member	Lightfoot adjudicated and dismissed the same claims; res judicata binds class members	Dismissed: res judicata bars Counts 1,3,4,5
D.C.‑law damages claim (Count 6)	Challenged requirement to seek reconsideration before a hearing	Court previously dismissed same claim for failure to show statutory notice to the Mayor; law‑of‑the‑case prevents relitigation	Dismissed: law‑of‑the‑case (failure to show six‑month notice)
Future/ prospective damages (Count 7)	Alleges injury if her condition worsens and she faces the same defective procedures in future	Risk of future procedural injury is speculative; no concrete, imminent injury	Dismissed for lack of jurisdiction: claim not ripe/no standing
As‑applied due‑process claim re: 2003 termination (Count 2)	She was denied meaningful process because medical reports relied on were not provided until the day of the hearing and the termination notice was vague; loss of benefits for six weeks caused harm	District had policy of making files available on request, she could have requested reconsideration to preserve benefits, was represented at the hearing, and cannot identify what additional evidence she would have presented if given earlier reports	Summary judgment for District: no due‑process violation (Mathews factors favor District given the record)

Apotex, Inc. v. FDA, 393 F.3d 210 (D.C. Cir.) (preclusion doctrine summarized)
Cooper v. Fed. Reserve Bank, 467 U.S. 867 (U.S.) (class action judgments bind class members)
Yamaha Corp. of Am. v. United States, 961 F.2d 245 (D.C. Cir.) (elements for issue preclusion)
Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (U.S.) (party asserting jurisdiction bears burden)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (U.S.) (plausibility standard for Rule 12(b)(6))
Ashcroft v. Iqbal, 556 U.S. 662 (U.S.) (pleading standards)
Mathews v. Eldridge, 424 U.S. 319 (U.S.) (three‑factor due process balancing)
Lujan v. Defenders of Wildlife, 504 U.S. 555 (U.S.) (standing requirements)
Abbott Labs. v. Gardner, 387 U.S. 136 (U.S.) (ripeness and avoidance of premature adjudication)
Richardson v. Perales, 402 U.S. 389 (U.S.) (reliability of written medical reports in administrative proceedings)