Mark R. Levy v. Howard County, Maryland, and Howard County Fire and Rescue Services

Summary

The United States District Court for the District of Maryland granted Defendants’ partial motion to dismiss Count Four of Mark R. Levy’s First Amended Complaint. The court held that the Declaratory Judgment Act does not create an independent cause of action and alternatively determined that the requested declarations were duplicative of Levy’s ADA discrimination claim.

Holdings

1. The Declaratory Judgment Act does not create an independent cause of action; it provides an alternative remedy for cases otherwise within federal jurisdiction. A plaintiff may not plead declaratory relief as a standalone substantive claim.
2. Declaratory relief should be dismissed when it merely duplicates the elements or liability determination of an existing ADA discrimination claim.

Questions Presented

1. Whether the Declaratory Judgment Act creates an independent cause of action that may be pleaded as a separate count.
2. Whether Levy's requested declarations concerning his disability, qualification, entitlement to the interactive process, and entitlement to reasonable accommodation were duplicative of his ADA discrimination claim.
3. Whether Count Four stated a claim for declaratory relief under Rule 12(b)(6).

Disposition

dismissed