Jangjoo v. Broadcasting Board of Governors, 244 F. Supp. 3d 160

Plaintiffs Soheila Jangjoo and Ardavan Roozbeh (POV contractors alleged to be de facto BBG employees) worked for BBG’s Persian News Network (PNN); Setareh Sieg was PNN Director and their supervisor.
After PNN removed a popular host (Siamak Dehghanpour), Jangjoo signed a Change.org petition supporting him; Jangjoo alleges reduced assignments, involuntary psychiatric detention, and de facto exclusion from BBG facilities.
Roozbeh managed PNN social media; he alleges Sieg pressured him to post favorable content, to remove comments about Dehghanpour, and recorded complaints in his file after he refused.
Roozbeh sent two resignation/grievance emails describing Sieg’s conduct; he alleges BBG then advanced his contract end date and sought a waiver of claims in exchange for administrative closure.
Plaintiffs sued BBG (claims for equitable relief and damages) and Sieg (individual-capacity First and Fifth Amendment claims). Defendants moved to dismiss in part; BBG asserted sovereign immunity.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether BBG may be sued for constitutional relief	Plaintiffs seek damages and equitable relief against BBG for First and Fifth Amendment violations	BBG asserts sovereign immunity bars suit absent a waiver	BBG entitled to sovereign immunity; Counts against BBG dismissed for lack of subject-matter jurisdiction
Whether Roozbeh’s First Amendment retaliation claim against Sieg survives	Roozbeh says he was retaliated against for whistleblowing/grievance emails about Sieg	Sieg contends Roozbeh spoke pursuant to official duties (Garcetti) so speech is unprotected	Dismissed: emails were employee speech made in the ordinary scope of duties; no First Amendment claim
Whether Roozbeh has standing for his procedural due process claim against Sieg	Roozbeh claims Sieg coerced termination and denied due process	Defendants contend he resigned (voluntary) so injury not fairly traceable to defendants; lack of standing and insufficient pleading	Dismissed: likely lacks standing because he resigned; claim also fails on the merits (no coercion/constructive discharge pleaded)
Whether Jangjoo’s First and Fifth Amendment individual-capacity claims against Sieg should be dismissed	Jangjoo alleges assignment reduction, involuntary commitment, exclusion from workplace as retaliation/denial of process	Defendants did not move to dismiss Counts I and III	Counts I and III allowed to proceed against Sieg in her individual capacity

United States v. Mitchell, 463 U.S. 206 (sovereign immunity requires waiver to sue the United States)
FDIC v. Meyer, 510 U.S. 471 (federal agencies protected by sovereign immunity absent waiver)
Garcetti v. Ceballos, 547 U.S. 410 (employee speech pursuant to official duties is unprotected by the First Amendment)
Lane v. Franks, 134 S. Ct. 2369 (Garcetti framework applied; focus on whether speech was pursuant to duties)
Mpoy v. Rhee, 758 F.3d 285 (D.C. Cir.: employee reports of misconduct within job duties are unprotected)
Winder v. Erste, 566 F.3d 209 (D.C. Cir.: speech reporting conduct that interferes with job responsibilities is unprotected)
Lujan v. Defenders of Wildlife, 504 U.S. 555 (standing requires injury, causation, redressability)
Taylor v. FDIC, 132 F.3d 753 (voluntary resignation can defeat causation/standing in employment claims)
Bd. of Regents v. Roth, 408 U.S. 564 (property interest in employment for due process analysis)
Bell Atlantic v. Twombly, 550 U.S. 544 (pleading must be plausible)
Ashcroft v. Iqbal, 556 U.S. 662 (legal conclusions not assumed true on a motion to dismiss)