Justia District of Columbia Court of Appeals Opinion Summaries

Claudia Allen sued the District of Columbia after being assessed a late payment penalty for a traffic ticket. Allen had timely mailed her payment using a pre-addressed envelope provided by the District, but the post office failed to deliver it, returning it as undeliverable. Allen claimed that the use of red ink on the pre-addressed envelopes caused the delivery failure, as it was difficult for USPS machines to read. She sought damages for negligence and aimed to certify a class of similarly affected individuals.The Superior Court of the District of Columbia granted summary judgment for the District on Allen's individual negligence claim, concluding that the evidence did not support a reasonable jury finding that the red ink caused the delivery failure. The court also denied her request for class certification, determining that she did not meet the Rule 23 requirements for a class action.The District of Columbia Court of Appeals reviewed the case and agreed with the lower court's decision. The court found that Allen's expert, Peter Wade, did not provide sufficient evidence to support the claim that red ink caused the delivery failure. Wade's testimony indicated that the likelihood of an envelope going undelivered was very low regardless of the ink color. The court also noted that Wade ultimately agreed with the District's expert, John Mashia, that the failed delivery was due to USPS error, not the red ink.The Court of Appeals affirmed the grant of summary judgment for the District, concluding that Allen did not present a viable negligence claim. Consequently, the court also affirmed the denial of class certification, as Allen could not represent a class without a valid individual claim. View "Allen v. District of Columbia" on Justia Law