Baker v. District of Columbia

Summary

The District of Columbia Court of Appeals held that an employee's defamation and intentional infliction of emotional distress claims arising from a work-related accusation were subject to the Comprehensive Merit Personnel Act. The court affirmed dismissal because the CMPA provided the exclusive remedy and Baker had not exhausted the applicable administrative procedures.

Holdings

1. The CMPA is the exclusive remedy for Baker's work-related defamation and intentional-infliction-of-emotional-distress claims because the alleged misconduct report concerned a matter under the control of the District government that adversely affected an employee's interests.
2. The CMPA applies even if Baker herself was not involved in a formal grievance proceeding; an employer's report of alleged employee misconduct may fall within the CMPA before a formal grievance is filed.
3. The presence of sexual-harassment or discrimination facts in the background of Baker's defamation claim did not trigger the exception to CMPA exclusivity.

Questions Presented

1. Whether Baker's defamation and related tort claims arising from a work-related accusation were subject to the Comprehensive Merit Personnel Act.
2. Whether the CMPA applied even though Baker had not herself been involved in a formal grievance proceeding.
3. Whether the Superior Court properly dismissed the complaint for failure to exhaust CMPA administrative remedies.

Disposition

affirmed