MacHie v. Nguyen
824 F. Supp. 2d 146
D.D.C.2011Background
- Pro se plaintiff Edmond Machie, a Cameroonian national, sues Dr. Charles Nguyen and Dr. Sameh Elsharkawy over alleged Title VI discrimination/retaliation and WIA discrimination, plus various common law claims.
- Plaintiff alleges a failing grade in CSC 522 by Elsharkawy during Spring 2006 due to race/national origin bias, with a later grade adjustment in December 2009 after a grade appeal.
- Nguyen placed plaintiff on academic probation for Fall 2007 and advised about non-readmission to the Master’s program (April 2010) due to GPA concerns.
- Plaintiff applied for readmission March 2010; he was denied in April 2010 because his GPA was below 3.0, despite a prior grade adjustment.
- Plaintiff alleged GPA-based discrimination and requested relief under Title VI, WIA, and various tort/defamation theories, which the court treats as procedural posture for dismissal.
- Defendants moved to dismiss under Rule 12(b)(6); plaintiff did not oppose, but the court proceeded to address merits.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Title VI individual liability viability | Machie argues individuals are liable under Title VI as discriminatory actors. | Nguyen/Elsharkawy contend Title VI does not permit individual liability. | No individual liability under Title VI; claim dismissed. |
| Private right of action under WIA | Machie contends WIA prohibits discrimination by funded programs and permits private action. | WIA does not authorize private plaintiffs to sue; funding/agency enforcement not shown. | WIA does not allow private suit; claim dismissed. |
| Common law false arrest | Machie alleges false arrest/illegal arrest by defendants. | No law enforcement role or arrest occurred; claim lacks basis. | No claim for false arrest stated. |
| Common law false charge | Machie asserts false charges against him. | No recognized cause of action for false charge in D.C. law. | False charge claim dismissed. |
| Defamation (slander/libel) | Machie alleges defamatory statements by defendants harmed reputation. | Plaintiff cannot show false statements published to third parties, or the requisite defamation elements. | Defamation claim dismissed. |
Key Cases Cited
- Ashcroft v. Iqbal, 129 S. Ct. 1937 (2009) (pleading standards requiring plausible claims)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (fact pleading to plausibility)
- Haines v. Kerner, 404 U.S. 519 (1972) (pro se pleadings held to less stringent standards)
- Jones v. Horne, 634 F.3d 588 (D.C. Cir. 2011) (courts construe pro se pleadings liberally)
- EEOC v. St. Francis Xavier Parochial Sch., 117 F.3d 624 (D.C. Cir. 1997) (standards for considering complaints and public records)
- Beeton v. District of Columbia, 779 A.2d 918 (D.C. 2001) (defamation elements and harm to standing)
- Pierce v. Community for Creative Non-Violence, 814 F.2d 663 (D.C. Cir. 1987) (defamation standard and speech injury)
- Scott v. District of Columbia, 101 F.3d 748 (D.C. Cir. 1996) (false arrest framework and factual sufficiency)
- Brown v. Carr, 503 A.2d 1241 (D.C. 1986) (malicious prosecution elements)