Andrea M. Hall v. The Fourth Judicial District and Chad C. Miller, in his official capacity

CourtDistrict Court, D. Colorado
DecidedJune 24, 2026
Docket1:25-cv-01138
StatusUnknown

This text of Andrea M. Hall v. The Fourth Judicial District and Chad C. Miller, in his official capacity (Andrea M. Hall v. The Fourth Judicial District and Chad C. Miller, in his official capacity) is published on Counsel Stack Legal Research, covering District Court, D. Colorado primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Andrea M. Hall v. The Fourth Judicial District and Chad C. Miller, in his official capacity, (D. Colo. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Judge Nina Y. Wang

Civil Action No. 25-cv-01138-NYW-MDB

ANDREA M. HALL,

Plaintiff,

v.

THE FOURTH JUDICIAL DISTRICT, and CHAD C. MILLER, in his official capacity,

Defendants.

ORDER

This matter is before the Court on Defendants’ Motion to Dismiss (or “Motion”). [Doc. 17]. The Motion is fully briefed. [Doc. 26; Doc. 29]. Upon review, the Court concludes that oral argument would not materially assist in the disposition of the Motion. For the following reasons, the Motion is respectfully GRANTED. BACKGROUND The following facts are drawn from the Verified Complaint and Jury Demand (“Complaint”), [Doc. 1], and taken as true for purposes of the Motion. Plaintiff Andrea M. Hall (“Ms. Hall” or “Plaintiff”) is an attorney. [Id. at ¶ 4]. In April 2023, she represented a defendant in a criminal trial in Colorado’s Fourth Judicial District (“the District”). [Id. at ¶ 8]. The presiding judge was Defendant Chad C. Miller (“Judge Miller”) (together with the District, “Defendants”). [Id.]. On the fourth day of trial, Ms. Hall experienced a severe “exacerbation of long- COVID,”1 which she had developed in February 2022. [Id. at ¶¶ 9–10]. The exacerbation “left Ms. Hall bedridden.” [Id. at ¶ 10]. Ms. Hall sought medical treatment but suffered an allergic reaction to the medication. [Id. at ¶¶ 11–12]. Knowing she would be unable to attend the next day of trial, Ms. Hall asked another attorney familiar with the case, Ingrid DeFranco (“Ms. DeFranco”),2 to appear on her behalf. [Id. at ¶¶ 12–13].

Ms. Hall notified Judge Miller’s division of her condition the next morning. [Id. at ¶ 14]. Ms. DeFranco appeared in court on her behalf and advised Judge Miller of the same. [Id. at ¶ 15]. Judge Miller questioned the veracity of Ms. DeFranco’s representations and expressed a belief that Ms. Hall was attempting to delay the trial. [Id. at ¶ 16]. He indicated that he would offer some accommodations for Ms. Hall and Ms. DeFranco, such as a private virtual meeting room and extra breaks, but these accommodations were never provided. [Id. at ¶¶ 20–21]. Judge Miller also ordered Ms. Hall to submit medical documentation. [Id. at ¶ 22]. He initially declined to seal Ms. Hall’s medical records but reversed course after Ms. DeFranco objected. [Id. at ¶¶ 25, 29].

The following Monday, Ms. DeFranco informed Judge Miller that she would try the remainder of the case with Ms. Hall’s remote assistance. [Id. at ¶ 26]. The day after that, Ms. Hall requested an extended lunch break so she could receive an intravenous medical

1 “Long COVID” generally refers to a range of symptoms that continue for at least three months after an initial COVID-19 infection. See Harvey V. Fineberg et al., A Long COVID Definition: A Chronic, Systemic Disease State with Profound Consequences 1–2 & box S-1 (2024). Ms. Hall does not specify what symptoms she experienced before, during, or after her “exacerbation,” see [Doc. 1], but the Court takes her factual allegations about her condition as true and follows the Parties’ lead in referring to her condition as “long COVID.” 2 Ms. DeFranco also represents Ms. Hall in this case. The Court takes no position on whether Ms. DeFranco is also a material witness who would be barred from representing Ms. Hall at trial. See [Doc. 17 at 3 n.2]. treatment. [Id. at ¶ 27]. Judge Miller refused. [Id.]. Ms. Hall’s symptoms worsened, and she was “unable to return to the trial.” [Id. at ¶ 28]. Judge Miller eventually granted the defense a mistrial after excluding certain testimony from the defense’s expert witness. See [id. at ¶¶ 30–33]. He ruled that Ms. Hall would not be permitted to retry the case without co-counsel. [Id. at ¶ 35].

Before and after the mistrial, Judge Miller “repeatedly accused Ms. Hall of grave misconduct and dishonesty[] and publicly defamed her,” presumably by reiterating his belief that she had misrepresented her symptoms in order to delay the trial. [Id. at ¶ 34]. He repeated these comments at the next status conference for the case and at sentencing. [Id. at ¶ 36]. And he “continues to hold that [Ms. Hall] may not try a case [before him] without co-counsel.” [Id. at ¶ 47]. Ms. Hall brings three claims against Judge Miller and the District. First, she asserts that they violated Title III of the Americans with Disabilities Act of 1990, as amended by the ADA Amendments Act of 2008 (collectively, “ADA”), by discriminating on the basis of

disability in a public accommodation (“Claim One”). [Id. at ¶¶ 37–43]; 42 U.S.C. § 12182. Second, she alleges that Defendants unlawfully retaliated against her for requesting an accommodation, in violation of Titles II and V of the ADA (“Claim Two”). [Doc. 1 at ¶¶ 44– 50]; 42 U.S.C. § 12203. Third, she claims that the alleged disability discrimination also violated the Rehabilitation Act of 1973 (“Claim Three”). [Doc. 1 at ¶¶ 51–57]; 29 U.S.C. § 794. Defendants move to dismiss all claims for lack of subject matter jurisdiction and failure to state a claim. [Doc. 17]. LEGAL STANDARDS I. Rule 12(b)(1) Rule 12(b)(1) provides that a complaint may be dismissed for “lack of subject- matter jurisdiction.” Fed. R. Civ. P. 12(b)(1). A Rule 12(b)(1) motion may be classified as a facial attack or a factual attack on subject matter jurisdiction. Each type of attack

implicates a different analytical framework. The Tenth Circuit has explained that: Motions to dismiss for lack of subject matter jurisdiction under Rule 12(b)(1) may take one of two forms. First, a party may make a facial challenge to the plaintiff’s allegations concerning subject matter jurisdiction, thereby questioning the sufficiency of the complaint. In addressing a facial attack, the district court must accept the allegations in the complaint as true. Second, a party may go beyond allegations contained in the complaint and challenge the facts upon which subject matter jurisdiction depends. In addressing a factual attack, the court does not presume the truthfulness of the complaint’s factual allegations, but has wide discretion to allow affidavits, other documents, and a limited evidentiary hearing to resolve disputed jurisdictional facts under Rule 12(b)(1).

United States v. Rodriguez-Aguirre, 264 F.3d 1195, 1203 (10th Cir. 2001) (cleaned up). “However, a court is required to convert a Rule 12(b)(1) motion to dismiss into a Rule 12(b)(6) motion or a Rule 56 summary judgment motion when resolution of the jurisdictional question is intertwined with the merits of the case.” Paper, Allied-Indus., Chem. & Energy Workers Int’l Union v. Cont’l Carbon Co., 428 F.3d 1285, 1292 (10th Cir. 2005) (quotation omitted). A jurisdictional question intertwines with the merits when “resolution of the jurisdictional question requires resolution of an aspect of the substantive claim.” Id. (quotation omitted). Defendants attached no exhibits to their Motion and attack only the sufficiency of the allegations in the Complaint. See [Doc. 17]. The Court therefore considers the Motion as a facial attack on jurisdiction. Ms. Hall asks the Court to convert the Motion to one for summary judgment because the “factual allegations are inextricably intertwined with the jurisdictional issues.” [Doc. 26 at 10].

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