Abdelhady v. George Washington University

District Court, District of Columbia·Decided February 25, 2025·No. Civil Action No. 2022-1334·Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

HDEEL ABDELHADY, Plaintiff,

v. Case No. 1:22-cv-01334 (TNM)

GEORGE WASHINGTON UNIVERSITY, et al.,

Defendants.

MEMORANDUM ORDER

Hdeel Abdelhady was leaving an adjunct professor appreciation luncheon at George Washington University Law School when she fell down a staircase. Amended Compl., ECF No. 13, ¶¶ 11, 17–24. She hurt her head and arm. Id. ¶¶ 17–19. Her suit seeks damages from four defendants: the University (GWU); its insurance administrator, PMA Management Corporation; and its facilities services contractors, Aramark Services, Inc. and Aramark Management Services, LP. Id. at 3–4, 68.

Over the past two years, this case has been litigated into procedural spaghetti. Amid three interlocutory appeals, one of which is pending, and 123 docket entries, the Court now faces four pending motions: a motion to dismiss Counts I and III of her complaint against the Aramark defendants with prejudice, Pl. Reply Mot. Dismiss, ECF No. 121; a request to enter partial final judgment for Abdelhady’s claims against GWU and PMA under Rule 54(b), ECF Nos. 112, 115–16; a motion to reopen the case until receiving a final judgment, Pl. Mot. Reopen

Case, ECF No. 122; 1 and a motion for an order on the first two listed motions, Pl. Mot. for Order, ECF No. 123.

Much of these motions’ verbiage discusses past events in this litigation. E.g., Pl. Mot.

Partial Judgment, ECF No. 112. But the Court trims the fat here. The focus remains on the procedural history and reasoning relevant to deciding Abdelhady’s claims today. Her motions will be decided as follows: The motion to dismiss Counts I and III with prejudice is granted; the Rule 54(b) motion is denied; and the motions to reopen and to issue an order are denied based on the first two holdings. The Court also addresses two other motions that Abdelhady claims have been pending in Section IV.

As one final note, the Court generally affords special solicitude to pro se litigants. But that policy does not extend to pro se lawyers representing themselves, as Abdelhady does. Spence v. U.S. Dep’t of Veterans Affairs, 109 F.4th 531, 538 & n.1 (D.C. Cir. 2024); see also Penkoski v. Bowser, 548 F. Supp. 3d 12, 19–20 (D.D.C. 2021). She is a practicing member of the D.C. Bar. Mem. Op., ECF No. 62, at 5. Throughout the reasoning below, the Court construes Abdelhady’s arguments as it would any counseled party.

I.

To begin, the Court considers whether it has jurisdiction over her motions after Abdelhady made a third interlocutory appeal to the D.C. Circuit.

She first appealed this Court’s minute order sealing just one of her medical exhibits in 2022. See Min. Order 9/26/2022. The D.C. Circuit vacated and remanded that order with instruction that this Court consider the Hubbard factors fully. Mandate of USCA, ECF No. 99.

1 The Court denies this motion as moot because it renders a final judgment on Counts I and III against Aramark. Her motion requests reopening the case until the “entry of a final judgment or the occurrence of another final event.” Pl. Mot. Reopen Case, ECF No. 122, at 3.

The Court did so, granting in part her request to seal more medical documents. Order, ECF No. 100. Now, she has appealed this Court’s sealing order again. Not. Appeal, ECF No. 110.

Throughout, Abdelhady has attempted to shoehorn this Court’s order on the merits into her sealing appeals. Shortly after she filed her first sealing appeal, this Court dismissed some claims and entered summary judgment for all others against the GWU and PMA defendants. Mem. Op. (Mem. Op. MTD/MSJ), ECF No. 62. Abdelhady amended her pending notice of appeal to include that merits decision as to GWU and PMA. Not. Interlocutory Appeal, ECF No. 71. She also asked this Court to render its order against GWU and PMA final under Rule 54(b) for appeal. Pl. Mot. Partial Judgment, ECF No. 69. The Court denied her motion because her pending claims against the Aramark defendants “ar[ose] from the same transaction and occurrence.” Mem. Order, ECF No. 87, at 4. In response, Abdelhady voluntarily dismissed her remaining claims against the Aramark defendants and filed amended notices of appeal. Min. Order 3/20/2023 (granting voluntary dismissal); Second Amend. Not. Appeal, ECF No. 95.

The D.C. Circuit nonetheless dismissed Abdelhady’s first attempt to appeal the merits order for lack of jurisdiction. Mandate of USCA, ECF No. 97. The order was not final and appealable because it did not “dispose of all claims against all parties.” Id. Her voluntary dismissal of the Aramark defendants did not engineer finality because those claims were dismissed without prejudice. Id. (citing Blue v. District of Columbia Pub. Schs., 764 F.3d 11, 17–18 (D.C. Cir. 2014)). Voluntary dismissals at the plaintiff’s request must be done with prejudice to be final and appealable. Blue, 764 F.3d at 17–18. The D.C. Circuit thus only resolved her sealing appeal. Mandate of USCA, ECF No. 99.

Now, Abdelhady is trying the same tack again. Her second record-sealing appeal ostensibly included only this Court’s new sealing order issued after remand. Not. Appeal, Doc.

2058377, Abdelhady v. George Washington Univ. (No. 24-7090) (D.C. Cir. June 7, 2024). But then when she designated the “underlying decisions from which appeal arises,” she filed both the sealing order and the merits order whose appeal had already been dismissed for lack of jurisdiction. Underlying Decisions at 1–2, Doc. 2063546, Abdelhady v. George Washington Univ. (No. 24-7090) (D.C. Cir. July 8, 2024). The D.C. Circuit unsurprisingly dismissed her appeal “insofar as appellant seeks review” of the GWU and PMA merits order. Order, Doc. 2078798, Abdelhady v. George Washington Univ. (No. 24-7090) (D.C. Cir. Oct. 8, 2024). Because the prior panel had dismissed the order for lack of jurisdiction, that holding became the law of the case. Id. The sealing issue remains pending on appeal for the second time. Id. Abdelhady now returns to this Court asking, once again, for a Rule 54(b) order from this Court rendering the claims against GWU and PMA finally decided. Pl. Mot. Partial Judgment, ECF No. 112. She again would like to include that merits order in her second sealing appeal. Id.

Key to this Court’s current jurisdiction is the D.C. Circuit order’s final line: “The Clerk is directed to withhold issuance of the mandate herein until resolution of the remainder of the appeal.” Order, Doc. 2078798, Abdelhady v. George Washington Univ. (No. 24-7090) (D.C. Cir. Oct. 8, 2024). Normally, the filing of a notice of appeal, including an interlocutory appeal, “confers jurisdiction on the court of appeals and divests the district court of control over those aspects of the case involved in the appeal.” United States v. DeFries, 129 F.3d 1293, 1302 (D.C. Cir. 1997). The district court usually “does not regain jurisdiction over those issues until the court of appeals issues its mandate.” Id. But there are a “few narrow exceptions to this rule, such as where the defendant . . . takes an interlocutory appeal from a non-appealable order.” Id. at 1302–03. The D.C. Circuit has already held twice that the GWU and PMA merits order is a non-appealable order. Order, Doc. 2078798, Abdelhady v. George Washington Univ. (No. 24-

7090) (D.C. Cir. Oct. 8, 2024); Mandate of USCA, ECF No. 97. Thus, this Court may exercise jurisdiction over the merits order because Abdelhady appealed a non-appealable order. DeFries, 129 F.3d at 1302–03.

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