Dorsey v. District of Columbia, 747 F. Supp. 2d 22

Plaintiff Michael Dorsey, pro se, sues the District of Columbia, the DMV, a DMV employee (Claytor), and a DMV contractor (ACS) alleging interference with his business assisting others with parking and moving violation matters.
District and Claytor file motions to dismiss arguing plaintiff lacks standing; the court grants these motions and sua sponte dismisses the remaining defendants.
Plaintiff alleges various DMV tactics and policies interfered with hearings, scheduling, and challenges to tickets, including purportedly discriminatory practices, changes to ticket formats, and a so-called “Dorsey Rules.”
Plaintiff asserts gender-based exclusion, false harassment claims by DMV personnel, preferential treatment of DC Council members, and FOIA-related issues.
Court determines the plaintiff lacks standing to challenge DMV decisions or to bring employment-discrimination claims, and dismisses federal claims for lack of standing; remaining state-law claims are dismissed without reaching merits.
Order grants the District’s and Claytor’s motions to dismiss; dismisses all remaining defendants sua sponte for lack of standing; declines supplemental jurisdiction over remaining defamation and FOIA claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether plaintiff has standing to sue.	Dorsey asserts standing based on his injury to his business from DMV actions.	District/Claytor contend plaintiff lacks injury in fact and cannot establish standing.	Plaintiff lacks standing; claims dismissed.
Whether plaintiff has standing to challenge alleged denial of fair hearings for ticket recipients.	Dorsey argues harms to his clients translate to his own standing.	Defendants argue injury is not to plaintiff personally.	Lack of personal injury; dismissed.
Whether plaintiff has standing to pursue employment/discrimination claims.	Plaintiff claims discriminatory practices at DMV.	No personal injury or adverse action shown against plaintiff.	No standing to pursue discrimination claims.
Whether the court should exercise supplemental jurisdiction over remaining FOIA/defamation claims.	Claims should be heard as part of the federal case.	Federal claims resolved; discretion to decline supplemental jurisdiction.	Declines supplemental jurisdiction; those claims dismissed.
Whether the case should be dismissed sua sponte for lack of standing as to non-moving defendants.	All defendants implicated in district actions.	Standing deficiencies apply across the board.	Dismissal sua sponte as to non-moving defendants.

Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (standing requires injury in fact and redressability)
Steel Co. v. Citizens for a Better Env't, 523 U.S. 83 (1998) (standing as threshold jurisdictional prerequisite)
City of Waukesha v. Envtl. Prot. Agency, 320 F.3d 228 (D.C. Cir. 2003) (standing and injury in fact framework in this circuit)
Tozzi v. Dep't of Health & Human Servs., 271 F.3d 301 (D.C. Cir. 2001) (injury must be concrete and particularized)
Rainbow/PUSH Coal. v. Fed. Commc'ns Comm'n, 396 F.3d 1235 (D.C. Cir. 2005) (stigmatizing injury requires personal or direct impact)
Goodman v. Fed. Commc'ns Comm'n, 182 F.3d 987 (D.C. Cir. 1999) (third-party standing requires hindrance to third party)
Reno v. American Civil Liberties Union, 521 F.3d 1147 (D.C. Cir. 2008) (illustrative of standing principles in similar contexts)
Reno v. ACLU, 199 F.3d 1352 (D.C. Cir. 2000) (standing and third-party participation considerations)
Am. Immigration Lawyers Ass'n v. Reno, 199 F.3d 1352 (D.C. Cir. 2000) (organization lacked standing where no direct injury)
Weaver's Cove Energy, LLC v. R.I. Dep't of Envtl. Mgmt., 524 F.3d 1330 (D.C. Cir. 2008) (sua sponte dismissal for lack of standing)
Shekoyan v. Sibley Int'l, 409 F.3d 414 (D.C. Cir. 2005) (supplemental jurisdiction considerations after federal claims dismissed)