Dawson v. Washington Metropolitan Area Transit Authority
2017 WL 2729070
D.D.C.2017Background
- Plaintiffs Arthur Dawson, Ronald Moore, and Gregory Peters were non‑represented supervisory employees of WMATA who sued for breach of contract, claiming WMATA’s Metro Policy/Instruction 7.5.1 (the “Policy”) guaranteed supervisors a salary at least 5% greater than their highest paid direct report.
- Complaint challenged only the Policy’s “comprehensive salary review” component and alleged WMATA failed to pay the 5% differential following periodic reviews.
- The Policy defines “compression” as when a supervisor’s pay is less than 5% above the highest paid direct report and describes periodic comprehensive salary reviews that consider compression along with equity, performance, and salary ranges.
- The Policy explicitly states comprehensive salary adjustments are subject to budgetary conditions and within the General Manager/CEO’s discretion; the General Manager may cap adjustments for fiscal or institutional reasons.
- WMATA moved for summary judgment on the threshold legal question whether the Policy created an enforceable contract; the Court ordered summary judgment briefing limited to that issue.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Policy creates an enforceable contract requiring a 5% pay differential | The Policy’s compression definition and comprehensive review create a contractual right to a 5% differential after review | The Policy is a discretionary compensation procedure, not a promise; adjustments are subject to budgetary limits and GM discretion | No contract exists; summary judgment for WMATA |
| Whether the Policy’s terms are sufficiently definite to enforce a specific pay obligation | The 5% benchmark is a clear, enforceable term | The Policy frames 5% as a diagnostic benchmark within a broader, discretionary review, not a guaranteed payment term | Term is not an enforceable, definite promise |
| Whether the parties manifested an intent to be bound by a 5% requirement | Plaintiffs say the Policy shows intent to bind WMATA to maintain the differential | WMATA’s reservation of discretion and budgetary contingencies show no intent to be bound | No mutual intent to be bound to a 5% obligation |
| Effect of discretion/budget clauses on contract formation | Plaintiffs did not rebut that discretion clauses permit exceptions but contend overall mandate remains | Defendant: discretion and budget conditions negate a binding obligation that could be enforced regardless of fiscal reality | Discretion and fiscal limits confirm no enforceable contractual commitment |
Key Cases Cited
- Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment burden rules)
- Anderson v. Liberty Lobby, 477 U.S. 242 (definition of materiality and genuine dispute at summary judgment)
- Duffy v. Duffy, 881 A.2d 630 (contract enforceability requires definite material terms)
- Jack Baker, Inc. v. Office Space Dev. Corp., 664 A.2d 1236 (contract formation requires agreement on material terms and intent to be bound)
- Rosenthal v. Nat’l Produce Co., 573 A.2d 365 (court cannot enforce a contract if terms are vague or indefinite)
- 1010 Potomac Assocs. v. Grocery Mfrs. of Am., Inc., 485 A.2d 199 (contract interpreted as a whole to give meaningful effect to all terms)
- Howard Univ. v. Lacy, 828 A.2d 733 (mutual intention to be bound is essential for a contract)