Williams v. Brennan, Civil Action No. 2017-1285

Background

Pro se plaintiff Paulette A. Williams sued sixteen defendants (Postal Service officials, APWU union officials, and an EEO counselor) alleging failure to accommodate disabilities, hostile work environment, retaliation, wrongful layoff, and due process violations; she sought injunctive relief and $4,440,000.
The United States Attorney appeared for eleven federal Postal Service defendants (including Postmaster General Megan Brennan); four APWU officials were represented by private counsel; an EEO Counselor (Dana Claybrooks) was named but not served.
Williams’s amended complaint lacked specific factual allegations against most named defendants and contained only general assertions about an allegedly unauthorized union settlement and denial of arbitration.
APWU officials moved to dismiss for failure to state a claim; the court ordered Williams to show cause about unnamed defendants and she filed multiple supplemental pleadings and motions (preliminary injunction, appointment of counsel, leave to amend).
The court parsed claims: dismissed ADA and due process claims as to federal defendants; dismissed claims against individual Postal employees under the Rehabilitation Act; dismissed claims against individual union officials and the EEO counselor for failure to plead facts; left only Rehabilitation Act claims against Postmaster General Megan Brennan in her official capacity; denied preliminary injunction and motions to appoint counsel; denied leave to amend without a proposed pleading.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of allegations against APWU individuals	Williams contends APWU settled her grievance without permission and the individual officers failed to fix it, barring arbitration	APWU says complaint contains no factual allegations about the individuals and individual union officers cannot be liable for union actions	Court: Dismissed claims against APWU individuals for failure to state a claim (Rule 12(b)(6))
Liability of individual union officers for money damages	Williams seeks relief tied to union’s grievance/settlement conduct	APWU relies on Postal Reorganization Act and precedent that judgment/enforcement targets the union, not individual officers	Court: Individual union officers not liable; claims dismissed; leave to amend to add APWU premature without proposed pleading
Applicability of ADA to federal employees	Williams asserts ADA discrimination/failure to accommodate	Federal defendants note ADA excludes the United States from the definition of "employer"	Court: ADA claims dismissed as a matter of law as inapplicable to federal employees
Proper defendants under the Rehabilitation Act and remaining claims / preliminary injunction	Williams alleges Rehabilitation Act violations by multiple Postal employees and seeks injunctive relief (restore to work, prevent future layoffs)	Defendants and court note Rehabilitation Act claims against agency heads only; injunctive relief requires likelihood of success and other preliminary injunction factors	Court: Rehabilitation Act claims dismissed as to all federal employees except Postmaster General Megan Brennan (official capacity); preliminary injunction denied for failure to show likelihood of success or imminent irreparable harm

Key Cases Cited

Haines v. Kerner, 404 U.S. 519 (1972) (pro se pleadings are held to less stringent standards)
Winter v. Nat. Res. Def. Council, Inc., 555 U.S. 7 (2008) (preliminary injunction standards require clear showing of entitlement)
Ahmed v. Napolitano, 825 F. Supp. 2d 112 (D.D.C. 2011) (ADA does not apply to the federal government as an employer)
Richardson v. Yellen, 167 F. Supp. 3d 105 (D.D.C. 2016) (Rehabilitation Act claims against federal employees must be brought against agency heads in their official capacity)
Price v. Union Local 25, 787 F. Supp. 2d 63 (D.D.C. 2011) (individual union officers cannot be held personally liable for money damages arising from union actions)