Jefferson v. Stinson Morrison Heckler LLP
249 F. Supp. 3d 76
| D.D.C. | 2017Background
- Rev. David L. Jefferson alleges multiple disabilities and that Stinson Morrison Hecker LLP failed to provide a requested computer/tablet for his deposition on Sept. 17, 2014, causing stress, hospitalization, and incapacity for a period him and his wife managed his affairs.
- Jefferson filed a complaint with the D.C. Office of Human Rights on Sept. 14, 2015; the Office dismissed it and affirmed dismissal, and Jefferson then sued in federal court (original complaint filed May 11, 2016; Third Amended Complaint at issue).
- Claims pleaded: violation of Title III of the ADA (injunctive relief only), violation of the D.C. Human Rights Act (compensatory/other damages), and intentional infliction of emotional distress under D.C. common law.
- Stinson moved to dismiss under Fed. R. Civ. P. 12(b)(1) and 12(b)(6), arguing lack of standing for the ADA claim, timeliness bar for the Human Rights Act claim, and failure to plead outrageous conduct for the emotional-distress claim.
- The court concluded Jefferson lacked Article III standing to seek injunctive relief under Title III (no concrete likelihood of future harm), the Human Rights Act claim was time-barred (limitations tolled only while administrative complaint was pending and Jefferson filed in federal court after toll ended), and the emotional-distress claim failed because the alleged conduct was not sufficiently outrageous.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing for ADA (Title III injunctive relief) | Jefferson argues ongoing litigation and potential future depositions make future harm likely | Stinson contends Jefferson cannot show a real/immediate threat of future violations or concrete plans to return to defendant’s premises | Dismissed for lack of Article III standing (no likelihood of future injury); ADA claim dismissed without prejudice |
| Timeliness of D.C. Human Rights Act claim | Jefferson contends tolling for mental incapacity (non compos mentis) from Sept.–Dec. 2014 should extend limitations | Stinson argues administrative tolling ended when D.C. OHR affirmed dismissal (Apr. 7, 2016) and Jefferson filed in court after limitations expired; Jefferson was not totally incapacitated | Human Rights Act claim barred by statute of limitations; dismissed with prejudice |
| Intentional infliction of emotional distress (IIED) | Jefferson alleges stress, hospitalization, and disclosed susceptibility to stress justify IIED claim | Stinson says failure to provide a laptop/tablet is not extreme/outrageous conduct and does not meet D.C. standard even if aware of susceptibility | IIED claim fails for failure to plead extreme or outrageous conduct; dismissed with prejudice |
| Scope/merits of ADA Title III (place of public accommodation) | Jefferson assumes deposition site is a public accommodation | Stinson argues, alternatively, that a deposition at a law firm is not a Title III place of public accommodation | Court did not decide the merits or public-accommodation issue because it lacked jurisdiction (standing) on ADA claim |
Key Cases Cited
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (standing requires concrete, particularized, and imminent injury)
- Ashcroft v. Iqbal, 556 U.S. 662 (plausibility standard for pleadings)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (plausibility pleading framework)
- Deck v. American Hawaii Cruises, Inc., 121 F. Supp. 2d 1292 (Title III injunctive-relief standing requires real/immediate threat)
- Hendel v. World Plan Executive Council, 705 A.2d 656 (definition of non compos mentis for tolling under D.C. law)
- Kerrigan v. Britches of Georgetowne, Inc., 705 A.2d 624 (D.C. standard for extreme/outrageous conduct in IIED claims)