Chase v. Washington Metropolitan Area Transit Authority

CourtDistrict Court, District of Columbia
DecidedJuly 9, 2026
DocketCivil Action No. 2025-2904
StatusPublished

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

Bluebook
Chase v. Washington Metropolitan Area Transit Authority, (D.D.C. 2026).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

) MICHAEL CHASE, et al., ) ) Plaintiffs, ) ) Civil Case No. 25-2904 (RJL) V. ) ) WASHINGTON METROPOLITAN AREA ) TRANSIT AUTHORITY, ) ) Defendant. ) _ _ _ _____ _ _ )

MEMORANDUM OPINION IA-,, July _ er_ , 2026 [Dkt. #5, 7, 10]

Plaintiffs Michael Chase, Teonna Chase, and minor Z.C. ("plaintiffs") sued

defendant Washington Metropolitan Area Transit Authority ("WMATA") for the allegedly

negligent driving of a WMATA Metrobus. There are three motions pending. As explained

further below, I will DENY WMATA's first motion to dismiss [Dkt. #5] as moot, DENY

plaintiffs' motion for leave to file an amended complaint [Dkt. #7] as moot, and GRANT

WMATA's second motion to dismiss [Dkt. #10] because plaintiffs conceded the motion

under Local Civil Rule 7(b), and, in any event, plaintiffs failed to state a claim of negligent

infliction of emotional distress.

BACKGROUND

Plaintiffs Michael Chase, Teonna Chase, and their two-year old child, Z.C., sued

defendant WMATA for negligence and negligent infliction of emotional distress. See Am.

1 Compl. [Dkt. #8]. Plaintiffs allege that on December 8, 2024, a WMATA Metro bus merged

lanes without yielding and struck plaintiffs' vehicle. Id. ,i,i 5-6. Plaintiffs sought medical

evaluations and treatment for their injuries. Id. ,i,i 8-9.

On July 15, 2025, plaintiffs filed suit in the Superior Court of the District of

Columbia. See Ex. 5 to Compl. [Dkt. # 1-5]. On August 28, 2025, WMATA removed the

case to this Court. See Notice [Dkt. #3]. On September 4, 2025, WMATA filed a Rule

12(b)(6) motion to dismiss arguing that plaintiffs' action exceeded the statute of limitations

and failed to state a claim for negligent infliction of emotional distress. See Def. 's Mot. to

Dismiss ("First Mot. to Dismiss") [Dkt. #5].

On September 18, 2025, plaintiffs opposed WMATA's Rule 12(b)(6) motion. See

Pls.' Opp'n [Dkt. #6]. That same day, plaintiffs moved for leave to amend their complaint.

See Pls.' Mot. for Leave to Amend Complaint [Dkt. #7]. Plaintiffs simultaneously filed an

amended complaint on the docket. See Am. Compl. [Dkt. #8].

On October 7, 2025, in response to plaintiffs' amended complaint, WMATA filed a

second Rule 12(b)( 6) motion to dismiss the negligent infliction of emotional distress claim.

See Def. 's Partial Mot. to Dismiss ("Second Mot. to Dismiss") [Dkt. # 1O]. Plaintiffs never

responded. The motions are now ripe.

LEGAL STANDARD

Under Federal Rule of Civil Procedure 15(a)(l), a party may amend its pleadings

"once as a matter of course" within 21 days of service or receipt of responsive pleadings.

After 21 days, a party must obtain the "opposing party's written consent or the court's

leave" to amend its complaint. Fed. R. Civ. P. 15(a)(2). "The grant or denial of leave to

2 amend is committed to the sound discretion of the district court, but the court should freely

give leave when justice so requires." Mann v. United States, 2022 WL 888181, at *2

(D.D.C. Mar. 24, 2022) (quoting De Sousa v. Dep 't of State, 840 F. Supp. 2d 92, 113

(D.D.C. 2012)). Courts may deny motions for leave to amend for "undue delay, bad faith

or dilatory motive ... or futility of amendment." Id.

When evaluating a Rule 12(b)(6) motion to dismiss for failure to state a claim, the

Court must determine whether the complaint "contain[s] sufficient factual matter, accepted

as true, 'to state a claim to relief that is plausible on its face."' Ashcroft v. Iqbal, 556 U.S.

662, 678 (2009) (quoting Bell At!. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). The

complaint cannot merely offer "labels and conclusions" or "a formulaic recitation of the

elements of a cause of action." Id. (quoting Twombly, 550 U.S. at 555). Rather, the plaintiff

must "plead[] factual content that allows the court to draw the reasonable inference that the

defendant is liable for the misconduct alleged." Id. However, the plaintiff "is entitled to

'the benefit of all inferences that can be derived from the facts alleged."' Islar v. Whole

Foods Mkt. Grp., Inc., 217 F. Supp. 3d 261,265 (D.D.C. 2016) (quoting Am. Nat'! Ins. Co.

v. FDIC, 642 F. 3d 1137, 1139 (D.C. Cir. 2011)).

ANALYSIS

I. WMATA's First Motion to Dismiss

WMATA's first motion to dismiss should be denied as moot because plaintiffs

subsequently filed an amended complaint. See McKeithan v. Boarman, 2011 WL 2669060,

at *1 (D.D.C. July 7, 2011) ("[B]y filing the amended complaint, the plaintiff rendered his

original complaint a nullity." (cleaned up)); see also Gray v. D.C. Pub. Schs., 688 F. Supp.

3 2d 1, 6 (D.D.C. 2010) ("When a plaintiff amends her complaint, it renders a motion to

dismiss that complaint moot.").

II. Plaintiffs' Motion for Leave to Amend

Plaintiffs' motion for leave to file an amended complaint is denied as moot because

plaintiffs could-and did-file an amended complaint as of right under Federal Rule of

Civil Procedure 15(a)(l)(B). According to Rule 15(a)(l)(B), a party "may amend its

pleading once as a matter of course" within "21 days after service of a motion under Rule

12(b)." Here, WMATA filed a Rule 12(b)(6) motion on September 4, 2025. See First Mot.

to Dismiss. Fourteen days later, on September 18, 2025, plaintiffs timely filed an amended

complaint. See Am. Comp1. Therefore, plaintiffs' motion for leave to amend their

complaint is moot. See Shipkovitz v. Barr, 2019 WL 1082161, at *5 (D.D.C. Mar. 7, 2019)

(denying plaintiff's Rule 15(a)(l) Motion for Leave to Amend as moot because the

amended complaint was timely filed as of right).

III. WMATA's Second Motion to Dismiss

WMATA's second motion to dismiss is granted both because plaintiffs conceded the

motion by failing to respond and because the motion succeeds on the merits.

First, Local Civil Rule 7(b) provides that "an opposing party shall serve and file a

memorandum of points and authorities in opposition to the motion" within "14 days of the

date of service or at such other time as the Court may direct"; otherwise the "Court may

treat the motion as conceded." Local Civil Rule 7(b) is a '"docket-management tool that

facilitates efficient and effective resolution of motions,' and we have yet to deem a

'straightforward application of Local Rule 7(b)' an abuse of discretion." Cohen v. Bd. of

4 Trs. of the Univ. of the Dist. of Columbia, 819 F. 3d 476, 480 (D.C. Cir. 2016) (quoting

Fox. v. Am. Airlines, Inc., 389 F. 3d. 1291, 1294 (D.C. Cir. 2004)); see also Dean v. Lange,

Kim & Dowell, LLP, 2026 WL 172423, at *l (D.D.C. Jan. 22, 2026) (applying Local Civil

Rule 7(b)). 1

Second, WMATA's motion to dismiss is granted because plaintiffs have failed to

state a claim for negligent infliction of emotional distress. To establish a claim for

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

Related

Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Fox v. American Airlines, Inc.
389 F.3d 1291 (D.C. Circuit, 2004)
American Nat. Ins. Co. v. FDIC
642 F.3d 1137 (D.C. Circuit, 2011)
Northwest Forest Workers Ass'n v. Lyng
688 F. Supp. 1 (District of Columbia, 1988)
Rice v. District of Columbia
774 F. Supp. 2d 25 (District of Columbia, 2011)
De Sousa v. Department of State
840 F. Supp. 2d 92 (District of Columbia, 2012)
Cohen v. Board of Trustees of the University
819 F.3d 476 (D.C. Circuit, 2016)
Islar v. Whole Foods Markets Group, Inc.
217 F. Supp. 3d 261 (District of Columbia, 2016)
Voacolo v. Federal National Mortgage Association (Fannie Mae)
224 F. Supp. 3d 39 (District of Columbia, 2016)
Bradley v. National Collegiate Athletic Association
249 F. Supp. 3d 149 (District of Columbia, 2017)
Hedgepeth v. Whitman Walker Clinic
22 A.3d 789 (District of Columbia Court of Appeals, 2011)
Kowalevicz v. United States
302 F. Supp. 3d 68 (D.C. Circuit, 2018)
Hawkins v. Wash. Metro. Area Transit Auth.
311 F. Supp. 3d 94 (D.C. Circuit, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
Chase v. Washington Metropolitan Area Transit Authority, Counsel Stack Legal Research, https://law.counselstack.com/opinion/chase-v-washington-metropolitan-area-transit-authority-dcd-2026.