Dade v. Washington Metropolitan Transit Authority

CourtDistrict Court, District of Columbia
DecidedOctober 17, 2025
DocketCivil Action No. 2025-0619
StatusPublished

This text of Dade v. Washington Metropolitan Transit Authority (Dade v. Washington Metropolitan 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
Dade v. Washington Metropolitan Transit Authority, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

DANIELLE DADE,

Plaintiff, Civil Action No. 25 - 619 (SLS) v. Judge Sparkle L. Sooknanan WASHINGTON METROPOLITAN AREA TRANSIT AUTHORITY,

Defendant.

MEMORANDUM OPINION

Danielle Dade alleges that the Washington Metropolitan Area Transit Authority

(WMATA) discriminated against her based on disability in violation of the Americans with

Disabilities Act (ADA). WMATA moves to dismiss under Federal Rule of Civil Procedure

12(b)(1), arguing that Ms. Dade’s claims are barred by WMATA’s Eleventh Amendment

sovereign immunity. The Court agrees and dismisses Ms. Dade’s complaint without prejudice.

BACKGROUND

The Court draws the facts, accepted as true, from the Plaintiff’s Complaint and

attachments. Wright v. Eugene & Agnes E. Meyer Found., 68 F.4th 612, 619 (D.C. Cir. 2023).

Ms. Dade was hired as a Special Project Manager at WMATA in 2019 and was eventually

promoted to Assistant Project Manager in 2022. Compl. ¶ 6, ECF No. 1. In the latter role,

Ms. Dade was supervised by the Director of Planning and Sustainability, Amy Mesrobian. Id.

Between November 2022 and April 2023, Ms. Dade took two periods of short-term

disability leave under the Family Medical Leave Act (FMLA)—first, for “mental health issues”

and then for “an injury she sustained in January 2023 which made walking and sitting for long periods of time difficult.” Compl. ¶¶ 8, 10. After returning to work, Ms. Dade was permitted to

telework full time as an ADA accommodation rather than just the two days usually allowed.

Compl. ¶ 11.

During 2022 and 2023, Ms. Dade alleges that Ms. Mesrobian repeatedly discriminated

against her based on disability in various ways. Ms. Dade claims that Ms. Mesrobian (1) imposed

more onerous supervision requirements because of her telework accommodation, Compl. ¶ 11;

(2) threatened that she would manage Ms. Dade in a more “hostile way” if she were not prevented

from doing so by the FMLA and ADA, id.; (3) requested that Ms. Dade complete work early that

was not yet due, Compl. ¶ 13; (4) suggested that Ms. Dade was not adequately explaining her work

because of disability, Compl. ¶¶ 14–15; (5) unfairly criticized Ms. Dade’s work and placed her on

a performance improvement plan even though Ms. Dade had previously received a “high

performer evaluation” from her old department, Compl. ¶ 17; and (6) interfered with Ms. Dade’s

transfer to another department, Compl. ¶ 20.

In April 2023, Ms. Dade filed a complaint with WMATA’s Equal Employment

Opportunity Office about Ms. Mesrobian’s discriminatory treatment. Compl. ¶ 12. In November

2023, she filed another EEO complaint alleging retaliation. Compl. ¶ 21. On December 1, 2023,

WMATA terminated Ms. Dade. Id.

Ms. Dade filed this lawsuit on March 3, 2025. She alleges that WMATA violated the ADA

by discriminating against her based on disability and failing to reasonably accommodate her

disability (Count I), and by retaliating against her for engaging in protected activity (Count II).

Compl. ¶¶ 22–37. On April 28, 2025, WMATA moved to dismiss for lack of subject-matter

jurisdiction. Mot. Dismiss, ECF No. 3. The motion is now ripe for review. Opp’n, ECF No. 5.

2 LEGAL STANDARD

“When a defendant brings a Rule 12(b)(1) motion to dismiss, the plaintiff must demonstrate

that the court indeed has subject-matter jurisdiction to hear [her] claims.” Hill v. U.S. Dep’t of

Interior, 699 F. Supp. 3d 1, 12 (D.D.C. 2023) (first citing Lujan v. Defs. of Wildlife, 504 U.S. 555,

561 (1992); and then citing U.S. Ecology, Inc. v. U.S. Dep’t of Interior, 231 F.3d 20, 24 (D.C. Cir.

2000)). And “[b]ecause the court may not address the plaintiff’s claims without subject-matter

jurisdiction, a motion to dismiss under Rule 12(b)(1) [also] imposes an affirmative obligation on

the court to ensure that jurisdiction is proper.” Himex Co. v. United States, 17 F. Supp. 3d 77, 79

(D.D.C. 2014). In reviewing a motion to dismiss for lack of jurisdiction under Rule 12(b)(1), courts

“construe the complaint liberally, granting plaintiff the benefit of all inferences that can be derived

from the facts alleged.” Thomas v. Principi, 394 F.3d 970, 972 (D.C. Cir. 2005) (internal quotation

marks and citations omitted).

DISCUSSION

WMATA argues that Ms. Dade’s complaint must be dismissed because WMATA enjoys

Eleventh Amendment immunity from claims brought under Title I of the ADA. The Court agrees.

WMATA is a mass transit system that was “created by an interstate compact among

Maryland, Virginia, and the District of Columbia.” Barbour v. Washington Metro. Area Transit

Auth., 374 F.3d 1161, 1163 (D.C. Cir. 2004). The D.C. Circuit has “consistently recognized that

in signing the WMATA Compact, Virginia and Maryland each conferred its immunity upon

WMATA, which therefore enjoys, to the same extent as each state, immunity from suit in federal

court based on its performance of governmental functions.” Jones v. Washington Metro. Area

Transit Auth., 205 F.3d 428, 432 (D.C. Cir. 2000); see also Barbour, 374 F.3d at 1163 (“WMATA

. . . enjoys the Eleventh Amendment immunity of the two signatory states.”); Morris v. WMATA,

3 781 F.2d 218, 219 (D.C. Cir. 1986) (“WMATA’s sovereign immunity exists because the

signatories have successfully conferred their respective sovereign immunities upon it.”).

When a state or state entity enjoys Eleventh Amendment immunity, it may be sued only if

(1) it waives its immunity and consents to suit, or (2) Congress exercises its enforcement power

under Section 5 of the Fourteenth Amendment to abrogate the state’s immunity. Barbour, 374 F.3d

at 1163. Here, there is no indication that WMATA has waived its immunity and consented to be

sued by Ms. Dade. Nor has WMATA’s immunity been abrogated by Congressional action. While

Ms. Dade’s Complaint does not identify the specific title of the ADA under which she seeks relief,

her claims appear to be brought under Title I, which addresses disability discrimination in

employment. And the Supreme Court has directly held that “Congress did not validly abrogate the

States’ sovereign immunity from suit by private individuals for money damages under Title I.”

Bd. of Trs. of Univ. of Alabama v. Garrett, 531 U.S. 356, 374 n.9 (2001).

In light of the above authorities, Ms. Dade’s claims for monetary damages under the ADA

must be dismissed. The same is true of her requests for declaratory and injunctive relief. See

Seminole Tribe of Florida v.

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Foman v. Davis
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Seminole Tribe of Florida v. Florida
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Board of Trustees of Univ. of Ala. v. Garrett
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Richardson, Roy Dale v. United States
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Thomas, Oscar v. Principi, Anthony
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Dade v. Washington Metropolitan Transit Authority, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dade-v-washington-metropolitan-transit-authority-dcd-2025.