Flannery v. District of Columbia Department of Health

CourtDistrict Court, District of Columbia
DecidedDecember 18, 2023
DocketCivil Action No. 2022-3108
StatusPublished

This text of Flannery v. District of Columbia Department of Health (Flannery v. District of Columbia Department of Health) 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
Flannery v. District of Columbia Department of Health, (D.D.C. 2023).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ____________________________________ ) ERIC J. FLANNERY, et al., ) ) ) Plaintiffs, ) ) v. ) Civil Action No. 22-3108 (ABJ) ) DISTRICT OF COLUMBIA ) DEPARTMENT OF HEALTH, et al., ) ) Defendants. ) ____________________________________)

MEMORANDUM OPINION

On October 13, 2022, Eric J. Flannery and the Drane Flannery Restaurant, LLC (“Drane

Flannery” or “the LLC”) filed a complaint against the District of Columbia Department of Health

(“D.C. Health”) and its Director, LaQuandra S. Nesbitt, seeking declaratory relief and damages.

Compl. [Dkt. # 1] at 1. Drane Flannery is an LLC owned by Eric Flannery, and the LLC owns a

restaurant called The Big Board, which Eric Flannery operates. Compl. ¶¶ 8–9. Plaintiffs allege

that the defendants unlawfully levied fines and other penalties against The Big Board for alleged

violations of restrictions imposed by the D.C. government as emergency health measures at the

height of the COVID-19 coronavirus pandemic. Compl. ¶¶ 1–7.

Pursuant to Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6), defendants moved to

dismiss plaintiffs’ claims for lack of subject matter jurisdiction and for failure to state a claim upon

which relief can be granted. Defs.’ Mot. to Dismiss Pls.’ Compl. [Dkt. # 8] (“Mot.”) at 1; Mem.

in Supp. of Mot. [Dkt. # 8] (“Mem.”) at 12. Plaintiffs opposed the motion, Pls.’ Resp. in Opp. to Mot. [Dkt. # 12] (“Opp.”), and the matter is fully briefed. See Reply in Further Supp. of Defs.’

Mot. to Dismiss Pls.’ Compl. [Dkt. # 17] (“Reply”).

For the reasons set forth below, the Court will GRANT defendants’ motion to dismiss.

BACKGROUND

On March 11, 2020, District of Columbia Mayor Muriel Bowser issued two emergency

executive orders. Compl. ¶ 23. The first declared that there was a “public emergency” in the

District of Columbia due to the COVID-19 coronavirus outbreak. Compl. ¶ 23, citing Mayor’s

Order 2020-045. 1 The second declared the presence of a “public health emergency” due to the

virus. Compl. ¶ 23, citing Mayor’s Order 2020-046. The orders were scheduled to remain in effect

for fifteen days unless rescinded or suspended at an earlier time. Compl. ¶ 23, citing Mayor’s

Order 2020-045; Mayor’s Order 2020-046.

On March 16, 2020, Mayor Bowser issued an order prohibiting “mass gatherings” and

restricting restaurants and taverns from seating customers at tables from that date until April 1.

Compl. ¶ 24, citing Mayor’s Order 2020-048. The next day, the D.C. Council issued an

amendment to the D.C. Code, which authorized the Mayor to extend the initial emergency

executive orders that would have otherwise expired under normal procedures. See Compl. ¶¶ 25–

26. The amendment authorized the mayor to extend those emergency orders for an additional 30

days, Compl. ¶ 26, citing D.C. Code § 7-2306(c-1) (as amended Mar. 17, 2020), and those to come.

See Compl. ¶¶ 21, 26–27 citing D.C. Code § 7-2306(c-1) (as amended Mar. 16, 2022).

1 In ruling upon a motion to dismiss for failure to state a claim, a court may ordinarily consider only “the facts alleged in the complaint, documents attached as exhibits or incorporated by reference in the complaint, and matters about which the Court may take judicial notice.” Gustave-Schmidt v. Chao, 226 F. Supp. 2d 191, 196 (D.D.C. 2002), citing EEOC v. St. Francis Xavier Parochial Sch., 117 F.3d 621, 624–25 (D.C. Cir. 1997); see Fed. R. Civ. P. 10(c).

2 Throughout the pandemic, the D.C. Council continued to pass emergency legislation

authorizing the mayor to extend emergency executive orders, and, in December of 2021, Mayor

Bowser issued two emergency orders of importance here: one imposing a mask requirement in

public spaces, and one requiring customers in bars and restaurants to show proof of vaccination.

See Compl. ¶ 3, citing Mayor’s Order 2021-147, 68 D.C. Reg. 13954 (Dec. 20, 2021) (imposing

an indoor mask requirement for restaurants and taverns when persons are not actively eating or

drinking); Mayor’s Order 2021-148, 68 D.C. Reg. 14222 (Dec. 22, 2021) (requiring proof of

vaccination for customers to enter restaurants and taverns).

On February 1, 2022, D.C. Health issued a Notice of Infraction and Notice of

Closure/Summary Suspension to Big Board for allegedly “permit[ing] a guest, visitor, or customer

over twelve (12) years old to enter their indoor premises without displaying proof of vaccination

against COVID-19” “[i]n violation of Mayor’s Order 2021-148 § II(1).” Ex. A to Compl.

[Dkt. # 1-1] (“Notice of Infraction”) at 1. The notice additionally alleged that The Big Board was

“[i]n violation of Mayor’s Order 2021-147 §IV(I)” because it “did not require all persons to wear

mask indoors when not actively eating or drinking.” Id.

Plaintiffs challenge the imposition of these fines and the summary suspension of The Big

Board’s license. The complaint includes three causes of action:

• Count I alleges that defendants acted ultra vires by regulating through rolling emergency and temporary legislation, rather than permanent legislation, in violation of 42 U.S.C. § 1983 and the D.C. Home Rule Act. Compl. ¶¶ 59–65.

• Count II alleges that D.C. Code § 7-2308, a pre-existing provision that authorizes the suspension of certain judicial review procedures required by the D.C. Administrative Procedure Act (“APA”) during a declared emergency, operated to violate plaintiffs’ due process rights under the Fifth Amendment to the U.S. Constitution. Compl. ¶¶ 66–71.

3 • Count III alleges that D.C. Health exceeded its regulatory authority by suspending The Big Board’s license in violation of the D.C. Administrative Procedure Act. Compl. ¶¶ 72–75.

• Count IV seeks a declaratory judgment pursuant to 28 U.S.C. § 2201. Compl. ¶¶ 76–78. See Compl. ¶ 79–80.

Plaintiffs seek compensatory and punitive damages, or in the alternative nominal damages,

as well as attorneys’ fees and other costs associated with this action. Compl. ¶¶ 82–83.

Plaintiffs also ask the Court for a declaratory judgment holding that “DC Health’s actions

in reliance on the D.C. Council’s emergency legislative amendments and the Mayor’s Orders are

contrary to law,” Compl. ¶ 79; a declaratory judgment holding that “D.C. Code § 7–2308’s bar on

a [D.C. APA] claim challenging DC Health’s actions . . . violates the Due Process Clause of the

U.S. Constitution,” Compl. ¶ 80; and a declaratory judgment holding that D.C. Health exceeded

its regulatory authority in violation of the D.C. APA. Compl. ¶ 81.

STANDARD OF REVIEW

In evaluating a motion to dismiss under either Rule 12(b)(1) or 12(b)(6), the Court must

“treat the complaint’s factual allegations as true, and must grant plaintiff ‘the benefit of all

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