Reaves-Bey v. Karr

Summary

The District of Columbia Court of Appeals held that the plaintiff's negligence claim, based on the defendants' alleged failure to protect her from a known danger, was subject to the three-year limitations period for negligence and presented a genuine issue of material fact. The court affirmed summary judgment on the wrongful-termination claim because the employment relationship was presumed to be at will and no applicable exception was shown. It reversed summary judgment on the negligence claim and remanded for further proceedings.

Holdings

1. A negligence claim based on an independent duty and distinct alleged breach is not necessarily governed by the limitations period applicable to an underlying assault merely because the claims arise from related conduct. Reaves-Bey's negligence claim was timely under the three-year limitations period for negligence.
2. Reaves-Bey presented sufficient evidence to create a genuine issue of material fact regarding whether appellees negligently exposed her to a known danger and whether that negligence proximately caused the assault and resulting injuries.
3. Summary judgment was proper on the wrongful-termination claim because, absent an express term of duration or limitation on discharge, employment is presumed terminable at will, and no public-policy exception was asserted.

Questions Presented

1. Whether the negligence claim was governed by the three-year limitations period for negligence rather than the one-year limitations period applicable to assault claims.
2. Whether Reaves-Bey presented a genuine issue of material fact on the negligence claim based on appellees' alleged independent duty to protect her from a known danger.
3. Whether Reaves-Bey presented a viable wrongful-termination claim where the employment relationship had no specified duration or limitation on discharge.

Disposition

other