McFadden v. Washington Metropolitan Area Transit Authority
949 F. Supp. 2d 214
D.D.C.2013Background
- McFadden, a pro se plaintiff, worked as a WMATA bus mechanic beginning in 2008.
- In 2009 he was diagnosed with ADHD and prescribed Adderall, but WMATA’s safety-sensitive policy barred amphetamine use, leading to a suspension after a positive drug test.
- At a 2011 Labor-Management Hearing, the individual defendants allegedly stated McFadden was a drug addict before his arrival.
- WMATA fired him for violating its substance-abuse policy but reinstated him later under an agreement with the union Local 689.
- McFadden sues for disability discrimination, retaliation, and defamation, seeking damages and other relief.
- Defendants move to dismiss certain ADA, Rehabilitation Act, defamation, and punitive damages claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether WMATA is immune from ADA claims in federal court. | McFadden contends ADA claims survive against WMATA. | WMATA argues Eleventh Amendment immunity bars ADA monetary relief against it. | ADA claim against WMATA dismissed with prejudice. |
| Whether the ADA and Rehabilitation Act claims may be asserted against the individual defendants. | McFadden asserts liability against individuals for discrimination and retaliation. | Individuals are not liable under ADA/Rehabilitation Act. | ADA and Rehabilitation Act claims against individuals dismissed with prejudice. |
| Whether the defamation claim is timely and properly pled against the individual defendants. | Discovery rule should toll accrual since he learned of statements July 2011. | Claims accrued March 2011; suit filed June 2012 is untimely. | Defamation claim not conclusively time-barred; discovery rule applied; issues of fact remain; claim not dismissed at 12(b)(6). |
| Whether the defendants are immune from punitive damages or whether WMATA may be liable for punitive damages. | Punitive damages sought against WMATA. | WMATA is not subject to punitive damages; immunity applies. | Punitive damages claim against WMATA dismissed (conceded). |
Key Cases Cited
- Barbour v. WMATA, 374 F.3d 1161 (D.C. Cir. 2004) (WMATA immune from private ADA claims under Eleventh Amendment via interstate compact)
- Bailey v. WMATA, 696 F. Supp. 2d 68 (D.D.C. 2010) (ADA claims against WMATA barred by immunity; district viewpoint on waiver)
- Hopps v. WMATA, 480 F. Supp. 2d 243 (D.D.C. 2007) (reiterates WMATA Eleventh Amendment immunity from ADA claims)
- Beebe v. WMATA, 129 F.3d 1283 (D.C. Cir. 1997) (defines WMATA immunity and scope under WMATA Compact)
- Di Lella v. Univ. of Dist. of Columbia, 570 F. Supp. 2d 1 (D.D.C. 2008) (no individual liability under ADA/Rehabilitation Act)
- Maupin v. Haylock, 931 A.2d 1039 (D.C. 2007) (discovery rule potentially applicable to defamation accrual in DC)
- Mullin v. Wash. Weekly, Inc., 785 A.2d 296 (D.C. 2001) (discovery rule may apply to non-mass-media defamation cases)
- Oparaugo v. Watts, 884 A.2d 63 (D.C. 2005) (defamation elements and publication requirements under DC law)
- Farrington v. Bureau of Nat. Affairs, Inc., 596 A.2d 58 (D.C. 1991) (consent as absolute defense to defamation; three-part test)
- Davis v. Grant Park Nursing Home LP, 639 F. Supp. 2d 60 (D.D.C. 2009) (treats unsettled state-law issues for choice of law)