Lockhart v. Coastal International Security, Inc.
2012 U.S. Dist. LEXIS 166330
| D.D.C. | 2012Background
- Plaintiffs Monique Lockhart and K.C. sued Coastal International Security in the District of Columbia, asserting multiple tort and wrongful discharge claims.
- Coastal moved to dismiss under Rule 41(b) for failure to prosecute and to follow court orders, and argued DOES jurisdiction over the claims.
- The court stayed the case to allow DOES to determine whether the DC Workers’ Compensation Act (WCA) applies, potentially precluding civil claims.
- The parties filed several status reports over months, with plaintiffs failing to provide documented proof of filing claims with DOES as ordered.
- The court lifted the stay on July 13, 2012 after persistent failure to show DOES filing, and granted the motion to dismiss certain counts while preserving others.
- The court ultimately held that Lockhart’s work-related tort claims (Counts I, III, IV, V) are barred by the WCA and dismissed, KC’s similar tort claims are dismissed for the same reason, but Count II (wrongful discharge) remains after denying dismissal under Rule 41(b).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Are Lockhart’s work-related tort claims barred by the WCA exclusivity? | Lockhart argues WCA does not bar her tort claims. | WCA exclusivity preempts these tort claims. | Yes; Counts I, III, IV, V dismissed. |
| Are KC’s tort claims barred by the WCA exclusivity? | KC’s claims fall outside employee scope and WCA exclusivity should not apply. | KC’s claims are preempted by WCA. | Yes; KC’s Counts I, III, and V dismissed. |
| Should Count II (wrongful discharge) be dismissed under Rule 41(b)? | Count II should proceed independent of WCA-related stays. | Count II should be dismissed for failure to prosecute under Rule 41(b). | No; Count II remains. |
| Did the court properly resolve the stay and primary-jurisdiction issues related to DOES? | DOES jurisdiction should control, delaying adjudication. | Referral to DOES should determine WCA applicability. | Court allowed DOES process as to remaining questions but proceeded with dismissal of counts under 12(b)/12(c) where appropriate. |
Key Cases Cited
- Vanzant v. Wash. Metro. Area Transit Auth., 557 F. Supp. 2d 113 (D.D.C. 2008) (WCA exclusivity preempts related tort claims when covered by act)
- Doe v. United States, 797 F. Supp. 2d 78 (D.D.C. 2011) (WCA exclusivity applies to work-related injuries precluding tort claims)
- Joyner v. Sibley Mem. Hosp., 826 A.2d 362 (D.C. 2003) (DOES does not have primary jurisdiction over some emotional distress claims; WCA coverage depends on relation to employment)