Jackson v. District of Columbia

Civil Action No. 25-302 (EGS) (D.D.C. Feb. 23, 2026) · United States District Court for the District of Columbia · February 23, 2026 · No. Civil Action No. 25-302 (EGS)

Summary

The United States District Court for the District of Columbia grants Defendants’ motion for partial summary judgment in Jacqueline Jackson’s employment-related action. The court holds that Jackson’s tort and hate-crime claims against the District, and against individual defendants in their official capacities to the extent applicable, are barred by her failure to comply with the notice requirements of D.C. Code § 12-309.

Holdings

  1. Jackson's claims in Counts 8, 9, 10, and 11 against the District were barred because she failed to provide the notice required by D.C. Code § 12-309.
  2. To the extent Jackson sued Lundgren and Peña in their official capacities, the claims were also barred by her failure to comply with D.C. Code § 12-309 because an official-capacity suit is treated as a suit against the District.

Questions Presented

  1. Whether Jackson's District of Columbia-law claims against the District were barred by her failure to comply with the written-notice requirement of D.C. Code § 12-309.
  2. Whether the same notice requirement barred the claims against the individual defendants to the extent they were sued in their official capacities.

Disposition

other

Cases Cited (8)

  • Frito-Lay, Inc. v. Willoughby, 863 F.2d 1029, 1034 (D.C. Cir. 1988)(cited)
  • Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 586-87 (1986)(cited)
  • Blocker-Burnette v. District of Columbia, 730 F. Supp. 2d 200, 203 (D.D.C. 2010)(cited)
  • Faison v. District of Columbia, 664 F. Supp. 2d 59, 68 (D.D.C. 2009)(cited)
  • Barnhardt v. District of Columbia, 601 F. Supp. 2d 324, 329 (D.D.C. 2009)(cited)
  • Gwinn v. District of Columbia, 434 A.2d 1376, 1378 (D.C. 1981)(cited)
  • District of Columbia v. Dunmore, 662 A.2d 1356, 1362 (D.C. 1995)(applied)
  • Crockett v. District of Columbia, Civil Action No. 16-1357, 2020 WL 1821121, at *7 (D.D.C. Apr. 10, 2020)(applied)

Cited In (0)

No citing cases on record yet.

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