Dahman v. Embassy Of Qatar, 364 F. Supp. 3d 1

Dahman, a longtime accountant for the Embassy of Qatar in Washington, had an employment contract that nominally expired when he turned 64 in 2011 but he continued working and was terminated in 2016.
He sued the Embassy and the State of Qatar in D.C. federal court alleging age discrimination under the ADEA and DCHRA; defendants were initially defaulted and the court entered judgment on liability.
Defendants later appeared and moved under Rule 60(b) to vacate the default judgment and to dismiss, arguing lack of jurisdiction, forum non conveniens based on an arbitration/forum-selection clause calling for arbitration in Doha under Qatari law, and immunity/exhaustion defenses.
The court exercised its discretion to decide forum non conveniens first, applying the Atlantic Marine two-step test for a contract forum-selection clause.
Key factual/legal disputes: whether the arbitration clause survived the contract’s stated expiration, whether it covers statutory ADEA/DCHRA claims and termination-related claims, and whether public-interest factors overwhelmingly disfavor dismissal to arbitration in Qatar.
The court concluded the contract’s arbitration clause remained binding, covers Dahman’s claims, and Dahman failed to show public-interest factors overwhelmingly disfavor arbitration; the court vacated the default judgment and dismissed on forum non conveniens grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of arbitration clause after contract expiration	Dahman: contract expired at age 64 in 2011, so arbitration clause no longer applies	Qatar: parties continued performance; terms (including arbitration) survived lapse	Court: applied ordinary-contract rule; continued performance implied renewal; clause remained binding
Scope of clause over statutory/discrimination claims	Dahman: clause limited or not meant to cover non-contractual ADEA/DCHRA claims and U.S. statutory violations	Qatar: clause broadly covers "any remaining dispute...arising out of or relating to" the contract, including statutory claims	Court: arbitration can cover statutory claims; clause language is broad and covers termination/discrimination claims
Whether U.S. law claims must be decided in U.S. courts/public-interest override	Dahman: ADEA/DCHRA policy and practical inability to vindicate rights in Qatar mean public interest forbids dismissal	Qatar: forum-selection clause controls; plaintiff must show public-interest factors overwhelmingly disfavor transfer	Court: Dahman failed to show Qatar could not adequately adjudicate claims or that public interest overwhelmingly disfavors arbitration; burden not met
Procedural relief (vacatur of default / dismissal)	Dahman: judgment should stand	Qatar: Rule 60(b) relief appropriate and forum non conveniens dismissal proper	Court: granted vacatur and dismissed on forum non conveniens grounds

Sinochem Int'l Co. v. Malaysia Int'l Shipping Co., 549 U.S. 422 (2007) (court may decide forum non conveniens before resolving jurisdictional questions)
Atlantic Marine Constr. Co. v. U.S. Dist. Ct., 571 U.S. 49 (2013) (two-step framework for enforcing forum-selection clauses)
Gilmer v. Interstate/Johnson Lane Corp., 500 U.S. 20 (1991) (statutory claims may be subject to arbitration)
Mitsubishi Motors Corp. v. Soler Chrysler-Plymouth, Inc., 473 U.S. 614 (1985) (arbitration clause need not specifically reference statutory claims)
Prima Paint Corp. v. Flood & Conklin Mfg. Co., 388 U.S. 395 (1967) (broad arbitration-language interpretation)
Steel Co. v. Citizens for a Better Environment, 523 U.S. 83 (1998) (court must ordinarily assure jurisdiction before other determinations)
Phoenix Consulting, Inc. v. Republic of Angola, 216 F.3d 36 (D.C. Cir. 2000) (forum non conveniens principles in D.C. Circuit)
Luden's Inc. v. Local Union No. 6, 28 F.3d 347 (3d Cir. 1994) (lapsed contract where parties continue performance implies renewal)