INDIRA POOLA v. HOWARD UNIVERSITY
147 A.3d 267
| D.C. | 2016Background
- Dr. Indira Poola, a South Asian female research professor at Howard University College of Medicine, was denied reappointment and locked out of her lab/offices in 2011 while she held active research grants (Komen, DoD, others).
- She sued the University and three faculty members asserting DCHRA discrimination, tortious interference, conversion, negligence, and breach of implied contract; some claims were dismissed below and partial summary judgment entered for the University on grant‑funded property.
- The trial court dismissed Poola’s DCHRA claims against all individual defendants and the University for failure to plead discriminatory nexus under Twombly/Iqbal and entered partial summary judgment that grant‑purchased equipment (and DoD supplies) belonged to the University.
- Poola stipulated to dismiss personal‑property claims set for trial to pursue appeal of dismissals and summary judgment rulings; she also sought inspection of property at the University but a protective order barred re‑entry/inspection.
- The D.C. Court of Appeals (this opinion) affirms dismissal of DCHRA claims versus two individuals (Cornwell, Frederick) as untimely/vague, reverses dismissal as to Dean Taylor and the University, affirms summary judgment as to equipment bought with Komen/DoD and DoD supplies, but reverses as to non‑equipment Komen purchases, “work product,” and the negligence claim; the protective order is vacated and remanded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of DCHRA pleadings (nexus/intent) | Poola: complaint alleged timely discriminatory acts by Taylor and a culture of gender/national‑origin discrimination; Twombly/Iqbal should not require prima facie proof at pleading stage | Univ/indivs: allegations were conclusory, speculative, lacked dates and nexus; some allegations outside limitations period | Reversed as to Taylor and University (pleading plausible; discovery warranted); affirmed as to Cornwell and Frederick (untimely/vague) |
| Ownership of equipment purchased with Komen and DoD grant funds (conversion) | Poola: she was PI, had contractual relations with funders, and had entitlement to items used in her research | Univ: grant documents (Komen) and OMB Circular A‑110 (DoD practice) vest title in grantee/recipient (the University); no evidence of deviating rules | Affirmed for equipment purchased with Komen or DoD funds and for supplies purchased with DoD funds (University entitled to judgment) |
| Ownership of non‑equipment Komen purchases and "work product" (conversion) | Poola: many items (supplies, samples, data, biological materials) are not clearly institutional equipment and may be her property or subject to possessory rights | Univ: broadly asserted institutional ownership/"work for hire" and relied on general policy statements | Reversed: genuine issues of material fact exist as to Komen non‑equipment items and alleged work product; cannot decide as matter of law—remand for further proceedings |
| Protective order and negligence claim (inspection and duty) | Poola: she needs inspection/expert access to assess condition/value and to prove negligence and damages; protective order improperly denied inspection | Univ: inspection would be disruptive, fishing expedition; items may be deteriorated or already inventoried; University asserted abandonment/ownership | Protective order vacated and remanded for proper balancing; negligence claim reversed from summary judgment (genuine issues about University duty and causation remain) |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility pleading standard requires factual content to allow reasonable inference of liability)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (conclusory allegations insufficient; court must consider plausible alternative explanations)
- Comer v. Wells Fargo Bank, N.A., 108 A.3d 364 (D.C. 2015) (D.C. adoption of Twombly/Iqbal and pleading analysis)
- Trustees of the Univ. of the Dist. of Columbia v. Vossoughi, 963 A.2d 1162 (D.C. 2009) (ownership of grant‑funded property generally vests in institutional grantee; factual distinctions may matter)
- Swanson v. Citibank, N.A., 614 F.3d 400 (7th Cir. 2010) (Twombly/Iqbal do not require a connect‑all‑the‑dots pleading in discrimination cases; simpler factual scenarios can be plausible)