White v. District of Columbia Water & Sewer Authority

Summary

The District of Columbia Court of Appeals affirmed a judgment awarding James White damages for breach of an implied employment contract against the District of Columbia Water and Sewer Authority. The court held that WASA's adoption of its own personnel and compensation system displaced application of the Federal Back Pay Act's attorney-fee provision. The court also upheld denial of reinstatement and additional job-related benefits because White had not shown manifest error or identified uncompensated benefits.

Holdings

1. WASA's adoption of its own personnel and compensation system exempted the Authority from the Comprehensive Merit Personnel Act's compensation provisions, including the Federal Back Pay Act's attorney-fee provision.
2. White was not entitled to reinstatement because he failed to show manifest error or manifest injustice in the trial court's refusal to grant that remedy, and reinstatement is not normally ordered in common-law breach-of-employment-contract cases absent a contractual provision authorizing equitable relief.
3. The trial court properly refused to award additional compensation for job-related benefits because White's conclusory argument did not identify any benefits allegedly lost beyond those reflected in the jury's monetary award and therefore did not establish manifest error.

Questions Presented

1. Whether employees of WASA remained entitled to attorney fees under the Federal Back Pay Act through the District of Columbia Comprehensive Merit Personnel Act.
2. Whether White was entitled to reinstatement as a remedy for his common-law breach-of-implied-employment-contract claim.
3. Whether the trial court erred by refusing to award additional compensation for unidentified job-related benefits.

Disposition

affirmed