Boutaugh v. District of Columbia

CourtDistrict of Columbia Court of Appeals
DecidedMay 22, 2025
Docket23-CV-0445
StatusPublished

This text of Boutaugh v. District of Columbia (Boutaugh v. District of Columbia) is published on Counsel Stack Legal Research, covering District of Columbia Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Boutaugh v. District of Columbia, (D.C. 2025).

Opinion

Notice: This opinion is subject to formal revision before publication in the Atlantic and Maryland Reporters. Users are requested to notify the Clerk of the Court of any formal errors so that corrections may be made before the bound volumes go to press.

DISTRICT OF COLUMBIA COURT OF APPEALS

No. 23-CV-0445

LAUREN D. BOUTAUGH, et al., APPELLANTS,

V.

DISTRICT OF COLUMBIA, APPELLEE.

Appeal from the Superior Court of the District of Columbia (2022-CAB-006003)

(Hon. Yvonne Williams, Motions Judge)

(Argued January 14, 2025 Decided May 22, 2025)

Matthew J. Focht, with whom Patrick G. Senftle and Marc L. Wilhite were on the brief, for appellants.

Holly M. Johnson, Senior Assistant Attorney General, with whom Brian L. Schwalb, Attorney General for the District of Columbia, Caroline S. Van Zile, Solicitor General, Ashwin P. Phatak, Principal Deputy Solicitor General, and Thais- Lyn Trayer, Deputy Solicitor General, were on the brief, for appellee.

Before EASTERLY, HOWARD, and SHANKER, Associate Judges.

PER CURIAM: Lauren and Joshua Boutaugh, a married couple, were both

sworn officers of the Metropolitan Police Department (MPD) in December 2020

when Ms. Boutaugh, who was approximately thirty-two weeks pregnant, contracted

COVID-19. Shortly thereafter, the couple’s baby, SMB, was delivered stillborn. An 2

autopsy determined that SMB’s death was caused by her exposure to the virus. The

Boutaughs sued the District of Columbia for negligence and wrongful death, alleging

that MPD had failed to protect Ms. Boutaugh, and thus SMB, from contracting

COVID-19. The Superior Court dismissed the action under Super. Ct. Civ.

R. 12(b)(6) on the grounds that the Boutaughs’ claims were barred by the public duty

doctrine. We review the dismissal of the Boutaughs’ complaint de novo,

“accept[ing] the allegations of the complaint as true[] and constru[ing] all facts and

inferences in favor of the plaintiff[s].” District of Columbia v. Amazon.com, Inc.,

320 A.3d 1073, 1079 (D.C. 2024) (quoting Grayson v. AT&T Corp., 15 A.3d 219,

228 (D.C. 2011) (en banc)). The District now concedes that the Boutaughs’

complaint plausibly pled that a special relationship existed between SMB and the

District through Ms. Boutaugh’s employment with MPD, thus establishing an

exception to the public duty doctrine. The District nonetheless defends the dismissal

of the complaint on the ground that the Boutaughs failed to plead any causal link

between the District’s breach of its duty to Ms. Boutaugh and SMB’s death. For the

reasons set forth below, we reverse.

I. Factual and Procedural Background

The Boutaughs allege the following facts in their complaint and thus, for the

purposes of our review, we accept them as true. In June 2020, the Boutaughs—both 3

police officers assigned to MPD’s Fifth District—learned that Ms. Boutaugh was

pregnant with their second child. At the time, MPD had in place certain policies

aimed at protecting the health and safety of its employees during the COVID-19

pandemic, including a mandatory telework policy for civilian administrative staff

(but not for sworn officers) at the Fifth District headquarters. Ms. Boutaugh notified

MPD of her pregnancy and was placed on a limited duty status, but she was still

required to report to work in-person at MPD’s Fifth District headquarters. In an

effort to avoid COVID-19 infection, Ms. Boutaugh “curtailed all outside activity,

remained masked at all times outside the home, including in the office, and limited

her contacts to work and home only.” Throughout Ms. Boutaugh’s pregnancy,

however, MPD “repeatedly failed to comply with” its own policies “concerning

mask-wearing, contact tracing, social distancing, health assessments and/or

temperature checks, self-quarantining, and limitations on access” to the Fifth District

headquarters.

On or around December 16, 2020, two officers in Mr. Boutaugh’s unit tested

positive for COVID-19. Although Mr. Boutaugh had been in close contact with

these officers, MPD’s contact tracing program failed to advise him of his exposure.

On December 18, Ms. Boutaugh went to work at the Fifth District for the last time

before falling ill. By December 19, Mr. Boutaugh had developed COVID-19

symptoms. On December 20, Ms. Boutaugh began experiencing symptoms, and 4

Mr. Boutaugh tested positive for the virus. Over the following week, Ms. Boutaugh

became seriously ill with COVID-19.

On December 31, 2020, at thirty-three weeks pregnant, Ms. Boutaugh

delivered the couple’s baby, SMB, stillborn. A fetal autopsy concluded that SMB’s

cause of death was “vascular malperfusion of the placenta due to maternal

COVID-19 infection with coagulopathy.” The fetus also appeared to itself be

infected with COVID-19, “more likely than not from transplacental transmission.”

The Boutaughs filed suit against the District, alleging negligence and

wrongful death on behalf of themselves and SMB. Their complaint asserted that,

“[h]ad the District of Columbia taken appropriate actions to protect pregnant sworn

[MPD] officers, such as [Ms. Boutaugh], from COVID-19 exposure, including, but

not limited to, permitting pregnant sworn officers to work from home . . . and

effectively implementing and enforcing the District’s own mask mandate, contact

tracing, health surveillance, quarantine, and/or infection control procedures, SMB

would today be a healthy toddler.” The District filed a motion to dismiss under

Super. Ct. Civ. R. 12(b)(6) for failure to state a claim upon which relief can be

granted, arguing that the Boutaughs’ claims were barred by the public duty doctrine,

“under which ‘the government and its agents are under no general duty to provide

public services . . . to any particular individual citizen.’” Hoodbhoy v. District of 5

Columbia, 282 A.3d 1092, 1097 (D.C. 2022) (quoting Klahr v. District of Columbia,

576 A.2d 718, 719-20 (D.C. 1990)).

The Boutaughs opposed the motion, arguing that the public duty doctrine did

not apply because, unlike other cases relied upon by the District, theirs did not

involve “the happening of an unexpected event and the failure of the District to

provide adequate rescue services to the plaintiff.” Instead, the Boutaughs argued,

“[h]aving put in place a policy requiring MPD sworn officers to remain at their MPD

worksites,” the District had a duty “to put in place and execute adequate safety

procedures, including contact tracing, to prevent COVID-19 exposure.” Even if the

public duty doctrine did apply, the Boutaughs further argued, an exception applied

because “a special relationship existed between SMB and the District of Columbia”

under the District’s Protecting Pregnant Workers Fairness Act (PPWFA), D.C. Code

§ 32-1231.01, and/or the telework policy issued by the District in response to the

pandemic, which “was specifically tailored to MPD sworn officers.”

The Superior Court concluded that (1) the public duty doctrine applied

because “SMB contracting COVID-19 through Ms. Boutaugh was the result of an

external threat,” rather than the result of “direct action” by the District, and (2) there

was no special relationship between the District and SMB. The court thus concluded

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Scheuer v. Rhodes
416 U.S. 232 (Supreme Court, 1974)
Croixland Properties Ltd. Partnership v. Corcoran
174 F.3d 213 (D.C. Circuit, 1999)
Klahr v. District of Columbia
576 A.2d 718 (District of Columbia Court of Appeals, 1990)
Wanzer v. District of Columbia
580 A.2d 127 (District of Columbia Court of Appeals, 1990)
District of Columbia v. Evans
644 A.2d 1008 (District of Columbia Court of Appeals, 1994)
Morgan v. District of Columbia
468 A.2d 1306 (District of Columbia Court of Appeals, 1983)
Turner v. District of Columbia
532 A.2d 662 (District of Columbia Court of Appeals, 1987)
McGee v. TOWNSHIP OF EAST AMWELL
7 A.3d 785 (New Jersey Superior Court App Division, 2010)
Grayson v. AT & T CORP.
15 A.3d 219 (District of Columbia Court of Appeals, 2011)
Sherry Allen and Wayne Allen v. District of Columbia
100 A.3d 63 (District of Columbia Court of Appeals, 2014)
Magaly Pinares v. United Technologies Corporation
768 F.3d 1161 (Eleventh Circuit, 2014)

Cite This Page — Counsel Stack

Bluebook (online)
Boutaugh v. District of Columbia, Counsel Stack Legal Research, https://law.counselstack.com/opinion/boutaugh-v-district-of-columbia-dc-2025.