Filed Date: Aug. 5, 2020
Case Ongoing
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In this case, the union representing the Distict of Columbia's Metropolitian Police Department sued the Mayor of the District Columbia and the city itself, challenging a local law that prohibited the union from negotiating police disciplinary rules during its collective bargaining process. D.C. police brought this suit under 42 U.S.C § 1983 on August 5, 2020 in the U.S. District Court for the District of Columbia. The union alleged that the Comprehensive Policing and Justice Reform Second Emergency Act, passed by the D.C. Council in the wake of the George Floyd protests in July of 2020, violated the Equal Protection clause, Due Process Clause, and the Contracts clause. The plaintiffs also alleged that the Act was a bill of attainder and violated the D.C. Home Rule Act. The plaintiffs were represented by a private law firm, and the case was assigned to the Honorable Judge James E. Boasberg.
The Union moved for summary judgment on all claims, while the District cross-moved for dismissal or, in the alternative, for summary judgment. On November 4, 2020, the Judge Boasberg ruled on the motions, holding for the District and dismissing the case without prejudice. 502 F.Supp.3d 45. The court dismissed the equal protection claims because it found that the Act's legislative history provided a rational basis for its treatment of the Union: the District sought to increase accountability for its officers. Next, the court explained why the bill of attainder claims were equally unfounded. Whether a legislative act amounts to a bill of attainder is determined by a two-part test: (1) does the law apply with specificity, and (2) does the law amount to punishment? The court dismissed the bill of attainder under the second prong because under the history, functional, and motivational sub-tests, it held the Act did not amount to punishment. As for the contract clause claim, even though the Act might affect future contracts between the Union and the District, the Constitution's Contract Clause is retrospective. The court held that the Union had not adequately shown that Act would impair a pre-existing contract. Finally, the court dismissed the Union's substantive due process claim because its stated interest—the right to collectively bargain for disciplinary procedures—was not constitutionally recognized.
The Union moved to amend its complaint following the dismissal, but it faced a high burden because the court had dismissed the case—not just the complaint. Under these circumstances, the Union must first win on either Rule 60(a) motion to correct a clerical mistake or a Rule 59(e) motion to amend the judgment. However, the court rejected the Union's Rules 60(a) and 59(e) motions on May 14, 2021. The court rejected the Rule 60(a) motion in short-shrift by affirming its decision to dismiss the case, and not just the complaint.
Next, the court addressed the Unions claim that the court had made a clear error or that its judgment resulted in a manifest injustice. The Union claimed that the court committed clear error by applying the wrong legal standard. Specifically, it claimed that the court misapplied the rational basis test and did not accept the complaint's factual assertions as true. The court disagreed with each argument, explaining its application of rational basis was proper and that the facts that the Union claimed the court did not honor were in fact legal conclusions. As for manifest injustice, the court rejected the Union's claim that denying it leave to appeal was unjust. The court reasoned that the general leeway given to plaintiffs to amend their complaint was absent under Rule 59(e). Finally, the court denied the Union's motion for leave to amend as moot, since neither 59(e) nor 60(a) were satisfied.
The Union appealed the District Court's order to the D.C. Circuit Court of Appeals on May 27, 2021.
As of February 2022, this case was ongoing.
Summary Authors
Jordan Katz (2/6/2022)
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/17415484/parties/fraternal-order-of-police-metropolitan-police-department-labor-committee/
Boasberg, James Emanuel (District of Columbia)
Conti, Anthony Michael (District of Columbia)
McCartin, Daniel J. (District of Columbia)
Disney, Pamela A. (District of Columbia)
Palmer, Gavin Noyes (District of Columbia)
Boasberg, James Emanuel (District of Columbia)
See docket on RECAP: https://www.courtlistener.com/docket/17415484/fraternal-order-of-police-metropolitan-police-department-labor-committee/
Last updated Feb. 26, 2024, 3:02 a.m.
State / Territory: District of Columbia
Case Type(s):
Key Dates
Filing Date: Aug. 5, 2020
Case Ongoing: Yes
Plaintiffs
Plaintiff Description:
Union for D.C. police challenging a D.C. law that prohibited the union from negotiating police disciplinary rules during its collective bargaining process.
Plaintiff Type(s):
Non-profit NON-religious organization
Public Interest Lawyer: No
Filed Pro Se: No
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
Defendant Type(s):
Case Details
Causes of Action:
Constitutional Clause(s):
Due Process: Substantive Due Process
Available Documents:
Outcome
Prevailing Party: Defendant
Nature of Relief:
Source of Relief: