Sampson v. D.C. Department of Corrections
20 F. Supp. 3d 282
| D.D.C. | 2014Background
- Sampson, a DOC corrections officer, alleged disability discrimination under the ADA in an amended complaint filed March 26, 2013.
- In 2006 an inmate threw feces at Sampson; he was diagnosed with PTSD and placed on light duty without inmate contact.
- Independent medical opinions in 2007 and subsequent evaluations recommended no direct inmate contact.
- Sampson was reassigned in 2009 to duties involving inmate transport, which Dr. Fisher did not approve; he became mentally unfit for certain duties and was hospitalized in 2009.
- DOC allegedly denied reinstatement of temporary total disability benefits in March 2009 and later events culminated in an ADA-related accommodation dispute.
- DOC moved to dismiss for lack of capacity and for untimely service; the District seeks substitution for the DOC and dismissal was denied.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the District should be substituted for the DOC as defendant | District substitution is proper because DOC lacks capacity to be sued. | Substitution is proper to cure non sui juris status of DOC. | District substituted for DOC; amended complaint treated as against District. |
| Whether service complied with Rule 4(m) timing | Service was timely within 120 days. | Service was untimely under Rule 4(m). | Service timely; District's motion denied. |
Key Cases Cited
- Howard Univ. v. Watkins, 857 F. Supp. 2d 67 (D.D.C. 2012) (12(b)(6) standard; facial plausibility)
- Peavey v. Holder, 657 F. Supp. 2d 180 (D.D.C. 2009) (Iqbal conjecture; plausibility standard)
- Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (plausibility standard for complaint sufficiency)
- Twombly, 550 U.S. 544 (U.S. 2007) (pleading must show plausible claim)
- Strong-Fischer v. Peters, 554 F. Supp. 2d 19 (D.D.C. 2008) (burden to show good cause for service delay)
- Ennis v. Lott, 589 F. Supp. 2d 33 (D.D.C. 2008) (agency capacity and substitute defendant)
- Hunter v. D.C. Child & Family Servs. Agency, 710 F. Supp. 2d 152 (D.D.C. 2010) (substitution of DC agency with District)