Williams v. District of Columbia
9 A.3d 484
| D.C. | 2010Background
- Williams was hired January 2008 as Associate Director of Athletic Programs for DPR.
- DPR youth basketball rules split Pee Wee (ages 6-8) and Pony (ages 9-10); eligibility hinges on age as of April 5 each year, with required age verification.
- February 2009: DPR staff received public complaints that Mayor Fenty’s sons played in Pee Wee despite eligibility; Williams learned of further complaints from parents.
- Williams contacted Mayor Fenty’s aide and learned Fenty’s children allegedly violated DPR rules; Ray admitted the violation and promised to address it.
- February 23, 2009: Ray terminated Williams for budgetary reasons and hinted Williams should “figure it out”; March 25, 2009: Williams testified before the Council about termination and Fenty’s sons’ conduct.
- The complaint alleges that after Williams spoke to the Council, District officials disseminated false reasons for termination (embezzlement).
- August 27, 2009: trial court granted defendants’ motion to dismiss; Williams appeals.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Williams made a protected disclosure under the DC-WPA. | Williams alleged he disclosed an abuse of authority and DPR rule violation by Fenty’s sons. | The information Williams reported was already publicly known and thus not a protected disclosure. | No protected disclosure under DC-WPA for the facts alleged. |
| Whether the defamation claim states a viable claim. | Complaint identified the substance of the statement (termination for embezzlement) and who within the DPR/Youth Sports sphere heard it. | Complaint lacked precise speaker, date, and recipients; insufficient specificity to state a defamation claim. | Reversed and remanded; defamation claim viable at pleading stage. |
| Whether Williams’ IIED claim survives. | Claim for intentional infliction of emotional distress affirmed as properly dismissed. |
Key Cases Cited
- Wilburn v. District of Columbia, 957 A.2d 921 (D.C. 2008) (DC-WPA protected disclosures; retaliation analysis)
- Crowley v. North Am. Telecomm. Ass'n, 691 A.2d 1169 (D.C. 1997) (defamation pleading standards; speaker identification considerations)
- Oparaugo v. Watts, 884 A.2d 63 (D.C. 2005) (timeframe for publication in defamation claims; pleading sufficiency)
- Beeton v. District of Columbia, 779 A.2d 918 (D.C. 2001) (elements of defamation claim; pleading standard)
- Futrell v. Department of Labor Fed. Credit Union, 816 A.2d 793 (D.C. 2003) (standards for IIED in employment context)
- Duncan v. Children's Nat'l Med. Ctr., 702 A.2d 207 (D.C. 1997) (outrageous conduct in employment context)
- Best v. Howard Univ., 484 A.2d 958 (D.C. 1984) (public policy/outrageous conduct considerations)