Vaughan v. Capital City Protective Services, II LLC
Civil Action No. 2020-2932
| D.D.C. | Jan 23, 2025Background
- Lakisha Vaughan was employed by Capital City Protective Services II, LLC as a Special Police Officer and alleges being subjected to sexual assault and subsequent sexual harassment by her supervisor and other male employees.
- In September 2018, Vaughan reported sexual harassment to several members of Capital City's management, including co-owner Armenta Bell, but claims no action was taken and that she was retaliated against.
- Vaughan filed a charge of sex discrimination and retaliation with the EEOC on November 7, 2018, which was cross-filed with local agencies, and obtained a right-to-sue letter before filing suit.
- During litigation, Armenta and Christopher Bell allegedly dissolved the original defendant company and created a successor, which Vaughan claims was an attempt to become judgment-proof.
- Vaughan amended her complaint after discovery revealed the Bells' alleged direct involvement, seeking to add them as defendants and to assert claims for fraudulent conveyance.
- The Bells moved to dismiss, arguing the claims against them were time-barred under the D.C. Human Rights Act's (DCHRA) one-year statute of limitations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Are the DCHRA claims against the Bells time-barred? | Claims were tolled by EEOC filing; amendment relates back; claims filed within a year of discovering Bells’ involvement. | Claims were filed more than a year after Vaughan’s employment ended; amendment adds new parties too late. | Claims are not facially time-barred: EEOC filing tolls the statute, and relation back doctrine and discovery rule defeat dismissal at this stage. |
| Can new defendants be added after the limitations period? | Rule 15(c) allows for relation back since claims arise from original occurrence and Bells were on notice. | Rule 15(c) allegedly does not allow relation back for new parties; citation to Brown v. Hill. | Rule 15(c) allows relation back where requirements are met; Brown v. Hill is inapposite. |
| Does the discovery rule apply to the accrual of claims? | Claims against Bells accrued when their personal involvement was discovered through discovery. | Discovery rule is inapplicable. | Discovery rule applies; when Vaughan discovered Bells’ involvement is a factual question unsuitable for judgment at this stage. |
| Grounds for dismissal on statute of limitations at pleadings stage | Not appropriate unless no viable response to defense; factual disputes remain. | Claims should be dismissed on face of pleadings. | Dismissal inappropriate because facts do not conclusively establish limitations bar. |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (establishes plausibility requirement for pleadings)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (complaint must state enough facts to be plausible on its face)
- Schuler v. PricewaterhouseCoopers, LLP, 514 F.3d 1365 (D.C. Cir. 2008) (filing an EEOC charge is treated as filing with DCOHR; tolling DCHRA limitation)
- Estenos v. PAHO/WHO Fed. Credit Union, 952 A.2d 878 (D.C. 2008) (DCHRA statute of limitations is tolled by agency filing)
- Farris v. Compton, 652 A.2d 49 (D.C. 1994) (discovery rule: claim accrues when plaintiff discovers, or should have discovered, the actionable conduct)