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Mathews-Baker v. Reynolds & Associates, Inc.
Civil Action No. 2015-1249
| D.D.C. | Oct 20, 2017
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Background

  • Mathews-Baker, indicted in a 2013 federal drug conspiracy case, lived in defendants’ D.C. halfway house from May–June 2015 pursuant to a court order; she pleaded guilty in April 2014 but judgment entered in Sept. 2015.
  • She sued defendants in Aug. 2015 alleging violations of the First, Fifth, Eighth, and Fourteenth Amendments, HIPAA, and discrimination arising from an alleged “no movement policy” (claims included denial of church attendance, law library access, medical care, work release, and staff disclosures to employers).
  • The plaintiff proceeded pro se, repeatedly failed to comply with discovery and court orders, and did not respond to defendants’ summary judgment motion; some claims (Eighth Amendment medical claims) were previously dismissed for failure to produce medical records.
  • Defendants submitted a Local Rule 7(h) statement and deposition excerpts showing plaintiff was permitted to attend church, attend job interviews, was represented by counsel, and appealed her conviction; the court treated defendants’ facts as admitted under Rule 56(e) and local rules.
  • The court concluded (after independent review) that defendants established no genuine dispute of material fact and that plaintiff’s claims fail as a matter of law; the HIPAA claim was dismissed for lack of a private right of action.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
First Amendment (church access, law library, redress) Defendants imposed a “no movement policy” that prevented church attendance, law-library access, and redress Deposition shows she was allowed church attendance (onsite or nearby), attended job interviews, had counsel, and no impediment to being heard Grant summary judgment for defendants; testimony defeats First Amendment claims
Fifth Amendment / Due process (access to counsel / redress) Denied ability to pursue redress in criminal case while at facility Record shows representation by counsel and no factual support for denial of redress; pleading insufficient Claim dismissed — insufficiently pled and unsupported by evidence
Discrimination (race, age, criminal-status) Discriminated against based on race, age, or criminal-case status Plaintiff only speculates (e.g., case manager’s race, feeling younger residents got favorable treatment); criminal status not protected Grant summary judgment; plaintiff offered no facts showing discriminatory purpose
HIPAA / Privacy HIPAA violation for staff disclosures of medical/employer info HIPAA does not provide a private right of action; enforcement reserved to HHS/DOJ Grant summary judgment; HIPAA claim dismissed as a matter of law

Key Cases Cited

  • Winston & Strawn, LLP v. McLean, 843 F.3d 503 (D.C. Cir. 2016) (courts may treat unopposed facts as admitted but must independently review the record)
  • Grimes v. District of Columbia, 794 F.3d 83 (D.C. Cir. 2015) (summary judgment principles when nonmoving party fails to oppose)
  • Celotex Corp. v. Catrett, 477 U.S. 317 (Sup. Ct. 1986) (moving party’s burden to identify absence of genuine issue)
  • Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (Sup. Ct. 1986) (materiality and summary judgment standard)
  • Ashcroft v. Iqbal, 556 U.S. 662 (Sup. Ct. 2009) (plaintiff must plead and prove discriminatory purpose for constitutional equal-protection claims)
  • Kimel v. Florida Bd. of Regents, 528 U.S. 62 (Sup. Ct. 2000) (age is not a suspect classification under equal protection)
  • Christopher v. Harbury, 536 U.S. 403 (Sup. Ct. 2002) (requirements for a Bivens/constitutional redress claim)
  • Bolling v. Sharpe, 347 U.S. 497 (Sup. Ct. 1954) (application of equal protection principles to the District of Columbia via Due Process)
  • Aetna Hudes v. Aetna Life Ins. Co., 806 F. Supp. 2d 180 (D.D.C. 2011) (HIPAA does not create a private right of action)
Read the full case

Case Details

Case Name: Mathews-Baker v. Reynolds & Associates, Inc.
Court Name: District Court, District of Columbia
Date Published: Oct 20, 2017
Docket Number: Civil Action No. 2015-1249
Court Abbreviation: D.D.C.
    Mathews-Baker v. Reynolds & Associates, Inc., Civil Action No. 2015-1249