Christina Williams v. Robert Johnson
414 U.S. App. D.C. 30
| D.C. Cir. | 2015Background
- Williams testified before the D.C. Council about ACIS failures and discrepancies between drafted and submitted Council answers.
- After the hearing, Williams was harassed by her supervisors, including removal of responsibilities and hostile treatment.
- ACIS Phase 1 was completed; Phase 2 progress lagged with conflicting timelines (July 2006 vs November 2006).
- Williams resigned in June 2007 after being effectively sidelined and left with no meaningful work.
- In 2010-2012, Williams amended her WPA claim to include constructive discharge and back/front pay; the District sought dismissal on notice grounds.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Williams' Council disclosure a protected WPA disclosure? | Williams exposed serious ACIS mismanagement and potential law/abuse. | Disclosures were not sufficiently serious under § 1-615.52(a)(6). | Yes; disclosures were sufficiently serious to be protected. |
| Did Williams experience a constructive discharge? | Harassment and removal of duties created intolerable conditions forcing resignation. | Conditions were not intolerable at resignation time. | Yes; working conditions were intolerable, supporting constructive discharge. |
| Is the notice requirement for WPA claims procedural or substantive post-amendment? | Notice requirement removed by 2010 amendment; retroactive application allowed. | Notice is a substantive constraint; amendment not retroactive. | Procedural; amendment retroactively applies to bar no claim. |
Key Cases Cited
- Wilburn v. District of Columbia, 957 A.2d 921 (D.C. Ct. App. 2008) (protective scope of WPA disclosures; serious misconduct standard)
- Freeman v. District of Columbia, 60 A.3d 1131 (D.C. Ct. App. 2012) (requires reasonable belief of seriousness; subjective belief not always needed)
- Lacek v. Washington Hospital Center Corp., 978 A.2d 1194 (D.C. Ct. App. 2009) (notice requirement procedural; retroactive application of procedural changes)
- Tucci v. District of Columbia, 956 A.2d 684 (D.C. Ct. App. 2008) (notice as condition precedent; sovereign immunity context)
- Brown v. United States, 742 F.2d 1498 (D.C. Cir. 1984) (distinct purposes of notice and limitations in waiver contexts)
- Aliotta v. Bair, 614 F.3d 556 (D.C. Cir. 2010) (employee prospects and discriminatory actions; constructive discharge context)
- Clark v. Marsh, 665 F.2d 1168 (D.C. Cir. 1981) (discriminatory actions and constructive discharge standards)