Battles v. Washington Metropolitan Area Transit Authority
272 F. Supp. 3d 5
| D.D.C. | 2017Background
- Plaintiff Sheldon Battles, a longtime WMATA employee, was terminated on November 27, 2015 after an internal investigation found he violated WMATA's nepotism/favoritism policy following a prior consensual sexual relationship with a subordinate and subsequent complaint.
- The Office of Civil Rights investigator found no probable cause for sexual harassment but recommended a violation of favoritism/nepotism; Superintendent Summon Cannon terminated Battles.
- Battles (pro se) sued WMATA and two employees (Summon Cannon and Devin Walker) asserting breach of contract (oral/implied), wrongful termination in violation of public policy, defamation, intentional infliction of emotional distress, and negligent infliction of emotional distress.
- Defendants moved to dismiss under Fed. R. Civ. P. 12(b)(1) and (6), arguing sovereign immunity and failure to state claims; Battles filed a late First Amended Complaint which the court struck for lack of leave.
- The Court denied dismissal of the breach-of-contract claim against WMATA (insufficient basis at motion stage to resolve application/exclusion of dispute-resolution policy or exhaustion), but dismissed with prejudice all tort claims against WMATA as barred by WMATA's sovereign immunity.
- The Court also dismissed with prejudice all claims against the Individual Defendants under the Compact (WMATA is the exclusive defendant for contract/tort liability arising from their official duties).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Battles' untimely First Amended Complaint should remain | Battles filed amended complaint and added exhaustion-related allegations | Defendants: amendment filed without consent or leave; untimely | Court struck the First Amended Complaint for failure to obtain consent or leave |
| Whether breach-of-contract (oral/implied or under employee dispute-resolution policy) survives dismissal | Battles: employee handbook/policy created enforceable contractual disciplinary procedures; not at-will | WMATA: either Battles was at-will or the policy excludes cases like his; also asserted failure to exhaust administrative remedies | Court: breach-of-contract claim survives at motion-to-dismiss stage — issues of policy application/exclusion and exhaustion are affirmative/uncertain and not resolved on Rule 12 motion |
| Whether WMATA is immune from Battles' state-law tort claims (wrongful termination/public policy, defamation, IIED, NIED) | Battles: seeks to avoid immunity (argues public-policy exception and cites federal statutes equalizing remedies) | WMATA: Compact and Section 80 preserve sovereign immunity for discretionary personnel decisions; tort claims barred | Court: WMATA immune for discretionary personnel/tort decisions; tort counts II–V against WMATA dismissed with prejudice |
| Whether Individual Defendants (Cannon, Walker) are personally liable | Battles: sues the supervisors/investigator individually on same contract and tort theories | Defs: Compact makes WMATA the exclusive defendant for contracts/torts committed in course of proprietary functions; employees immune when acting within scope | Court: Individual Defendants acted within official duties and discretionary functions; claims against them dismissed with prejudice |
Key Cases Cited
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (plaintiff bears burden to establish subject-matter jurisdiction)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plausibility standard for pleadings)
- Ashcroft v. Iqbal, 556 U.S. 662 (complaint must contain factual matter sufficient for plausible claim)
- Haines v. Kerner, 404 U.S. 519 (pro se complaints entitled to liberal construction)
- Beebe v. Washington Metro. Area Transit Auth., 129 F.3d 1283 (WMATA personnel decisions are discretionary and immune)
- KiSKA Const. Corp. v. Washington Metro. Area Transit Auth., 321 F.3d 1151 (two-part test for discretionary vs. ministerial functions under WMATA Compact)
- Banneker Ventures, LLC v. Graham, 798 F.3d 1119 (discretionary acts involve judgment/policy and are immunized)
- Jerome Stevens Pharm., Inc. v. FDA, 402 F.3d 1249 (courts may consider materials outside pleadings when resolving jurisdictional challenges)
- Morris v. Washington Metro. Area Transit Auth., 781 F.2d 218 (WMATA may invoke state sovereign immunity under the Compact)