Justia District of Columbia Court of Appeals Opinion Summaries

Appellant Yvonne Gant sued The Lynne Experience LTD (TLE) and Giant Foods, LLC (Giant) for negligence after allegedly being struck and injured by a golf cart operated by a TLE employee. Gant claimed that TLE and Giant failed to properly train and supervise their employees, leading to her injuries. TLE moved to dismiss the case, arguing that the District of Columbia’s Workers’ Compensation Act (WCA) provided Gant’s exclusive remedy, thus removing the court’s jurisdiction over the matter. The Superior Court agreed, dismissing Gant’s claims against TLE with prejudice, and later granted summary judgment in favor of Giant, finding no employer-employee relationship that could support Gant’s negligence claim.The Superior Court determined that the WCA provided Gant’s exclusive remedy and that the District of Columbia Department of Employee Services (DOES) had primary jurisdiction over her claims. The court dismissed Gant’s claims against TLE with prejudice, reasoning that any claim under the WCA would be time-barred. Subsequently, the court granted summary judgment for Giant, based on undisputed evidence that Giant was merely a sponsor of the event and had no role in managing or supervising the staff involved.On appeal, Gant argued that TLE failed to secure payment of compensation as required by the WCA and that she should be allowed to maintain her civil action. Alternatively, she requested a stay to present her claim to DOES. The District of Columbia Court of Appeals agreed that the WCA appeared to provide Gant’s exclusive remedy but held that the Superior Court should have dismissed her claim without prejudice. The court affirmed the summary judgment in favor of Giant, noting that Gant failed to present any arguments against it on appeal.The main holding by the District of Columbia Court of Appeals was that the Superior Court should have dismissed Gant’s claim against TLE without prejudice, allowing her the opportunity to pursue her claim with DOES. The court affirmed the summary judgment for Giant, as there was no evidence to support an employer-employee relationship necessary for Gant’s negligence claim. View "Gant v. The Lynne Experience, LTD" on Justia Law

Two employees sued their employers, alleging underpayment for work at a restaurant due to improper wage deductions for meal breaks. The employers deducted thirty minutes twice daily for breakfast and lunch breaks, but the employees claimed their breaks lasted only ten to fifteen minutes each.The Superior Court of the District of Columbia held a bench trial and found in favor of the employers, concluding that the breaks lasted at least twenty minutes. The court based its decision on the credibility of the employees' testimony and other evidence, including testimony from another employee and the restaurant's rules. The employees appealed, arguing that the trial court's findings were clearly erroneous and that the breaks should have been classified as compensable rest periods.The District of Columbia Court of Appeals reviewed the case and determined that the trial court had clearly erred in its evaluation of the employees' credibility and the evidence. The appellate court noted that the trial court misunderstood key aspects of the employees' testimony and other evidence. Consequently, the appellate court vacated the trial court's judgment and remanded the case for further examination of the evidence.The appellate court did not decide whether the breaks should be classified as rest periods, as this determination depends on the length of the breaks, which the trial court must reassess on remand. The burden of proof remains on the employees to demonstrate that their meal breaks were compensable. View "Sanchez v. Sundely" on Justia Law

Christian Greene, the Ombudsman for the District of Columbia Child & Family Services Agency (CFSA), was terminated from her position and subsequently filed a lawsuit against the District, claiming her termination violated the District of Columbia Whistleblower Protection Act (WPA). Greene argued that her termination was in retaliation for her disclosures about CFSA's non-compliance with the Foster Youth Statements of Rights and Responsibilities Amendment Act of 2012 (FYAA).The Superior Court of the District of Columbia granted summary judgment in favor of CFSA, concluding that Greene's disclosures were merely policy disagreements about the role of the Ombudsman and not protected under the WPA. The court did not address whether Greene reasonably believed her disclosures revealed unlawful activity or whether there was a causal connection between her disclosures and her termination.The District of Columbia Court of Appeals reviewed the case and found that Greene's disclosures were indeed protected under the WPA. The court held that Greene reasonably believed her disclosures revealed violations of the FYAA, which required CFSA to report on the outcomes of investigations and ensure compliance with relevant laws. The court noted that Greene's belief was genuine and reasonable, given the evidence she provided and the context of her role.The Court of Appeals reversed the trial court's grant of summary judgment in part and remanded the case for further proceedings. The trial court was instructed to determine whether there is a genuine dispute of material fact regarding whether Greene's WPA-protected disclosures were a cause of her termination. View "Greene v. D.C. Child & Family Services Agency" on Justia Law

Skylar Meinhardt, a former professional soccer player for the Washington Freedom, sustained a left knee injury in 2001 or 2002. Years later, she developed a right knee disability, which she attributed to compensating for her earlier left knee injury. Meinhardt claimed that her altered gait due to the left knee injury led to the deterioration of her right knee, resulting in pain first reported in 2015 and necessitating surgeries in 2016 and 2019.An Administrative Law Judge (ALJ) denied Meinhardt's workers' compensation claim, mistakenly framing the issue as whether a right knee injury in 2002 was related to the left knee injury in 2001. The ALJ found Meinhardt non-credible, partly because of her prior right knee surgeries in 1996, 1999, and 2001, and because the evidence did not support a right knee injury in 2002. The Compensation Review Board (CRB) affirmed the ALJ's decision, also mischaracterizing the issue as whether a 2002 right knee injury was related to the 2001 left knee injury.The District of Columbia Court of Appeals vacated the CRB's order and remanded the case for further proceedings. The court clarified that the central issue was whether Meinhardt's 2015 right knee disability was causally connected to her 2001-2002 left knee injury. The court found that both the ALJ and CRB had misunderstood the claim, leading to an erroneous denial of benefits. The court also noted that the evidence used to rebut the presumption of compensability, particularly a letter from Dr. Clinton Soppe, was not specific and comprehensive enough, as it incorrectly stated that Meinhardt's right knee pain began acutely in 2016.The case was remanded to the CRB, with instructions to remand it further to the ALJ for reconsideration, focusing on whether the 2015 right knee disability was causally related to the 2001-2002 left knee injury. View "Little v. D.C. Dep't of Employment Services" on Justia Law