Robinson v. District of Columbia
200 F. Supp. 3d 104
| D.D.C. | 2016Background
- Plaintiff, a District of Columbia Parks and Recreation employee, alleges work-related injuries on June 29, 2007, to his right arm, neck, shoulder, and lower back and received some treatment thereafter.
- He claims the District's Office of Risk Management channeled injured workers to certain doctors and, to save money, denied or limited proper and prompt medical care for over six years.
- Plaintiff alleges violations of constitutional and statutory rights and brings the action under 42 U.S.C. § 1983 seeking large compensatory and punitive damages and injunctive relief.
- The District moved to dismiss under Fed. R. Civ. P. 12(b)(6) for failure to state a claim; plaintiff filed several motions including for summary judgment and appointment of counsel.
- The complaint asserted Eighth, Fifth (due process), Fourteenth (equal protection), and related claims against the District and unnamed individual defendants; plaintiff alleged he exhausted administrative remedies.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the complaint states an Eighth Amendment claim for denial of medical care | The District's denial/limitation of medical care amounted to cruel and unusual punishment | Plaintiff is not a prisoner; Eighth Amendment inapplicable | Dismissed — no Eighth Amendment claim stated |
| Whether the complaint states a Fourteenth Amendment due process/equal protection claim | Plaintiff claims denial of due process and equal protection regarding workers' comp medical care | Fourteenth Amendment does not apply to D.C.; allegations are conclusory and lack facts showing unequal treatment | Dismissed — Fourteenth Amendment inapplicable; equal protection inadequately pleaded |
| Whether the complaint states a Fifth Amendment (procedural due process) claim against D.C. | Plaintiff alleges ‘‘abuse of medical process’’ and denial of procedural protections under D.C. workers' comp scheme | District contends allegations are vague, conclusory, and fail to identify the deprivation of a specific process or the process owed | Dismissed — plaintiff failed to allege what process was due or actually denied |
| Whether municipal liability under § 1983 is established | Plaintiff attributes a policy/custom of the Office of Risk Management to the District causing harm | District argues plaintiff offers no factual link tying any official policy/custom to constitutional violations | Dismissed — no underlying constitutional violation or adequately pleaded policy/custom; Monell liability not shown |
Key Cases Cited
- Erickson v. Pardus, 551 U.S. 89 (2007) (pro se complaints are to be liberally construed)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility standard for pleadings)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading must contain factual content to state a plausible claim)
- Monell v. Dep't of Soc. Servs. of the City of New York, 436 U.S. 658 (1978) (municipal liability requires a policy or custom causing the constitutional violation)
- West v. Atkins, 487 U.S. 42 (1988) (§ 1983 liability requires action under color of state law)
- Bolling v. Sharpe, 347 U.S. 497 (1954) (Fourteenth Amendment does not apply to the District of Columbia)
- Mathews v. Eldridge, 424 U.S. 319 (1976) (standard for what process is due)
- Bd. of Regents of State Colls. v. Roth, 408 U.S. 564 (1972) (property interest and entitlement analysis)
- Morrissey v. Brewer, 408 U.S. 471 (1972) (process due in parole revocation context; analysis on what procedure is required)
- City of Revere v. Massachusetts Gen. Hosp., 463 U.S. 239 (1983) (governmental duty to provide medical care to persons in custody)