Robinson v. Securitas Services, Inc.
819 F. Supp. 2d 18
| D.D.C. | 2011Background
- Robinson was employed as a security guard with Securitas, assigned to DC Public Schools.
- She was terminated on October 14, 2010 after an incident at Ballou High School for alleged training/policy violations.
- Robinson claimed lack of training, equipment, and staffing and alleged pay issues prior to termination.
- She filed suit in DC Superior Court on January 11, 2011, which was removed to federal court.
- Defendant moved to dismiss or grant summary judgment on Count II; Court analyzed Rule 12(b)(6) standards and dismissed all counts.
- Plaintiff asserted wrongful termination, breach of contract, and defamation; the court found at-will status and insufficient pleadings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Wrongful termination under public-policy exception | Robinson argues termination violated public policy. | There is no causal link or identifiable public policy. | Public-policy exception not satisfied; dismissal affirmed. |
| Breach of contract claim viability | Claim alleges contractual breach by employer. | At-will status bars contractual claim. | Count II deemed conceded and dismissed; at-will status forecloses claim. |
| Defamation claim adequacy | Defendant published false information to cover termination. | Defamation pleadings are insufficiently specific. | Defamation claim dismissed for lack of particularity. |
Key Cases Cited
- Adams v. George W. Cochran & Co., Inc., 597 A.2d 28 (D.C. 1991) (narrow at-will public-policy exception; replacement doctrine)
- Carl v. Children’s Hospital, 702 A.2d 159 (D.C. 1997) (public-policy exception requires identifiable official policy; close fit)
- Davis v. Gables Residential/H.G. Smithy, 525 F. Supp. 2d 87 (D.D.C. 2007) (public policy must be identified and linked to termination)
- Chisholm v. District of Columbia, 666 F. Supp. 2d 96 (D.D.C. 2009) (lack of clearly articulated public policy invalidates claim)
- Liberatore v. Melville Corp., 168 F.3d 1326 (D.C. Cir. 1999) (cites public-policy considerations in termination cases)
- Freas v. Archer Services, Inc., 716 A.2d 998 (D.C. 1998) (precedent allowing wrongful-termination claim when statute violated)
- Washington v. Guest Services, Inc., 718 A.2d 1071 (D.C. 1998) (public policy established; whistleblower-like context)
- Wiggins v. District Cablevision, Inc., 853 F. Supp. 484 (D.D.C. 1994) (defamation pleading requires time, place, content, speaker, and listener)