Tyler, Jr. v. Washington Metropolitan Area Transit Authority
53 F. Supp. 3d 101
D.D.C.2014Background
- Plaintiff applied for a WMATA security officer position in Nov 2010 with a conditional offer conditioned on medical/psychological determinations.
- In Oct 2011, Tyler had an interview, physical exam, and psychological evaluation by WMATA.
- In May 2012 WMATA informed him he did not meet employment standards based on the psychological evaluation.
- Tyler filed an EEOC discrimination claim the following month; EEOC closed the case Jan 14, 2014 and advised a lawsuit within 90 days.
- On Apr 11, 2014 Tyler filed the Rehabilitation Act claim in this court; WMATA moved to dismiss as time-barred under Rule 12(b)(6).
- Court denied WMATA’s motion, finding timely filing based on tolling and borrowed limitations rules.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Which limitations period governs Rehab Act claims in this district | Tyler argues for a three-year DC personal injury limit. | WMATA relies on Jaiyeola’s one-year limit under DC law. | Court need not decide borrowing; tolling applied, making suit timely. |
| Whether the limitations period was tolled during the EEOC proceedings | EEOC proceedings tolled the statute. | Not expressly tolling for Rehab Act claims. | tolling applied under DC law; EEOC period tolled the clock. |
| When the limitations period began and ended for timeliness | Start in May 2012; tolled from June 2012 to Jan 14, 2014; filing in Apr 2014 was within one year. |
Key Cases Cited
- Spiegler v. District of Columbia, 866 F.2d 461 (D.C. Cir. 1989) (borrowing/state tolling when no federal statute of limitations exists)
- Wilson v. Garcia, 471 U.S. 261 (Supreme Court 1985) (borrowed limitations and tolling principles; application to federal claims)
- Johnson v. Railway Express Agency, Inc., 421 U.S. 454 (Supreme Court 1975) (tolling provisions apply when borrowing state statutes)
- Jaiyeola v. District of Columbia, 40 A.3d 356 (D.C. 2012) (one-year limit under DCHRA for Rehab Act claims (disputed binding precedent))
- Adams v. District of Columbia, 740 F. Supp. 2d 173 (D.D.C. 2010) (recovery/limitations treatment in Rehab Act context; tolling considerations)