Amobi v. Brown

Amobi v. Brown

Opinion

MEMORANDUM OPINION

In 2006, the D.C. Department of Corrections ("DOC") summarily removed Plaintiff Stephen Ifeanyi Amobi from his position as a correctional officer. (See 2d Am. Compl., ECF No. 188, ¶¶ 12, 14.) Amobi successfully contested his removal through administrative proceedings, and was reinstated to his position. [*2]  (See id. ¶ 19.) He then initiated the instant legal action against the District of Columbia and multiple DOC officials (see id. ¶ 2), seeking damages for various alleged violations of federal and D.C. law with respect to his removal (see id. ¶¶ 30-40, 46-56). Amobi's federal claims were ultimately dismissed, but the majority of his D.C. law claims proceeded to trial (see Ct. Summ. of Remaining Counts for Trial, ECF No. 270), where a jury determined that one of the individual defendants, Devon Brown, had engaged in malicious prosecution of Amobi's removal (see Verdict Form, ECF No. 301, at 1).¹ Following the jury's verdict, the Clerk of Court entered judgment in Amobi's favor on his malicious prosecution of administrative removal claim and in favor of Brown and the other defendants on all remaining claims. (See J. on the Verdict, ECF No. 304, at 1.)

Before this Court at present is Brown's Renewed Motion for Judgment as a Matter of Law, or, in the Alternative, to Alter or Amend the Judgment. (See Def.'s Renewed Mot. for J. as a Matter of Law or, Alternatively, Mot. to Alter or Amend J. ("Def.'s Mot."), ECF No. 321.) In his motion, Brown contends that the D.C. Comprehensive Merit Personnel Act ("CMPA"), D.C. Code § 1-601.01 et seq., preempts Amobi's malicious prosecution [*3]  of administrative removal claim, because the CMPA provides the exclusive remedy for virtually all workplace grievances that are brought by employees of the District of Columbia. (See Def.'s Mot. at 11-14; Def.'s Suppl. Mem. in Supp. of Mot. ("Def.'s Suppl. Mem."), ECF No. 327, at 7-8.) Brown argues further that, because Amobi failed to exhaust his administrative remedies under the CMPA, the Court must dismiss Amobi's claim either for lack of subject-matter jurisdiction or for failure to state a claim upon which relief can be granted. (See Def.'s Suppl. Mem. at 7-8, 14.) In the alternative, Brown insists that the jury lacked a "legally sufficient evidentiary basis for [its] finding of liability" on Amobi's malicious prosecution of administrative removal claim, and he therefore asks the Court to reverse the judgment against him. (Def.'s Mot. at 14.) Amobi opposes Brown's motion on both grounds, arguing that the CMPA does not bar his claim, and that the evidence presented at trial supports the jury's verdict. (See Pl.'s Opp'n to Def.'s Mot. ("Pl.'s Opp'n"), ECF No. 324, at 6-7, 8-14; Pl.'s Resp. to Def.'s Suppl. Mem. ("Pl.'s Suppl. Mem."), ECF No. 329, at 4-5.)

This Court has carefully [*4]  considered the parties' submissions in this case, and for the reasons discussed fully below, it concludes that Amobi's malicious prosecution of administrative removal claim must be dismissed under Rule 12(b)(6) for failure to exhaust his administrative remedies under the CMPA's exclusive remedial framework. Consequently, Brown's motion will be GRANTED insofar as it seeks dismissal of the malicious prosecution of administrative removal claim under Rule 12(b)(6), and the judgment against Brown with respect to that claim will be VACATED. A separate Order consistent with this Memorandum Opinion will follow.

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