Mapp v. District of Columbia, 993 F. Supp. 2d 26

Monica Mapp, former probation officer for the DC Superior Court, sues the District alleging discrimination under FMLA, DCFMLA, Title VII, ADA, and DCHRA.
District moves to dismiss Counts IX, X, and XIII of the Amended Complaint on the ground that DCHRA does not apply to DC Superior Court employees.
Court analyzes whether the DCHRA conflicts with the DC Reorganization Act of 1970 and the Home Rule Act of 1973, which govern court personnel policies and independence.
Reorganization Act reserves control of court personnel to a Joint Committee and exempts court personnel from DC employee laws.
Home Rule Act preserves the DC courts’ structure and limits on local council authority over court organization and jurisdiction.
Court holds DCHRAinapplicable to DC Superior Court and Court of Appeals employees; Counts IX, X, XIII dismissed and a related stay/filing order issued.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does DCHRA apply to DC Superior Court employees?	Mapp argues DCHRA can regulate court personnel.	Reorganization/Home Rule Acts preclude council regulation of court personnel.	DCHRA does not apply to court employees.

Shutack v. Shutack, 516 F. Supp. 219 (D.D.C. 1981) (historic dual-role DC court context)
Palmore v. United States, 411 U.S. 389 (1973) (DC court reorganization and local government sovereignty)
United States v. Braxtonbrown-Smith, 278 F.3d 1348 (D.C. Cir. 2002) (statutory interpretation and plain language rule)
Food & Drug Admin. v. Brown & Williamson Tobacco Corp., 529 U.S. 120 (2000) (statutory interpretation in context of overall scheme)
District of Columbia v. John R. Thompson Co., 346 U.S. 100 (1953) (Congressional supremacy over local legislation)
Garrido-Morato v. Gonzales, 485 F.3d 319 (5th Cir. 2007) (interpretation of 'relating to' language)
United States v. Abdur-Rahman, 708 F.3d 98 (2d Cir. 2013) (statutory interpretation and contextual reading)