CURWEN v. DISTRICT OF COLUMBIA INTERNATIONAL SCHOOL
1:24-cv-02948
| D.D.C. | Jul 15, 2025Background
- Nicholas Curwen, a long-time teacher at District of Columbia International School (DCI), experienced a severe mental health crisis in summer 2023, exhibiting symptoms later attributed to schizoaffective bipolar disorder.
- Curwen made multiple requests to DCI for job accommodations and/or leave related to his mental illness; DCI did not respond to these requests, and neither did the school respond to requests from Curwen’s parents for accommodations on his behalf.
- On August 18, 2023, Curwen sent an incoherent email to the school with the subject line "I QUIT" while experiencing a mental health crisis. DCI treated this as a resignation, sent a severance agreement while Curwen was hospitalized, and continued to characterize his status as resigned.
- Curwen alleges he was coerced into signing the severance agreement to maintain insurance coverage, and that he remained unable to make employment decisions due to his mental health at that time.
- Curwen brought suit for violations of the ADA, DCHRA, FMLA, and DCFMLA, as well as to rescind the severance agreement on incapacity grounds. DCI moved to dismiss all claims under Rule 12(b)(6).
- The court granted dismissal on discrimination (failure to accommodate) claims, but denied dismissal for retaliation, FMLA/DCFMLA interference, and rescission of the severance agreement.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| ADA/DCHRA Discrimination (Accommodation) | Curwen was disabled, sought reasonable accommodation, and DCI failed to provide it. | Curwen was not a qualified individual, and did not adequately show ability to perform essential job functions with or without accommodation. | Dismissed: Plaintiff failed to allege ability to perform essential job functions. |
| ADA/DCHRA/FMLA/DCFMLA Retaliation | Curwen engaged in protected activity (requests for accommodation), and DCI took adverse action (coercion to sign severance) as retaliation. | Curwen voluntarily resigned; no protected activity prior; adverse action argument inapplicable. | Not dismissed: Allegations sufficient for retaliation claims to proceed. |
| FMLA/DCFMLA Interference | DCI failed to grant or acknowledge lawful requests for medical leave, resulting in prejudice. | Curwen resigned, so was not an employee at time of alleged interference. | Not dismissed: Allegations sufficient; factual disputes remain. |
| Rescission of Severance Agreement | Curwen lacked mental capacity to sign, DCI took advantage of incapacity, contract should be voidable. | Plaintiff must first return benefits received; agreement has not been enforced. | Not dismissed: Sufficient to proceed on rescission theory. |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (Rule 12(b)(6) pleading standard)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plausibility standard for complaints)
- Hill v. Assocs. for Renewal in Educ., Inc., 897 F.3d 232 (failure to accommodate elements under ADA)
- Haynes v. Williams, 392 F.3d 478 (definition of disability under ADA)
- Clayborne v. Potter, 448 F. Supp. 2d 185 (standards for ADA and Rehab Act liability are the same)
- Smith v. District of Columbia, 430 F.3d 450 (ADA retaliation analysis follows Title VII framework)