J.T.F. v. District of Columbia

CourtDistrict Court, District of Columbia
DecidedMarch 18, 2025
DocketCivil Action No. 2021-1453
StatusPublished

This text of J.T.F. v. District of Columbia (J.T.F. v. District of Columbia) 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
J.T.F. v. District of Columbia, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

J.T.F., et al., : : Plaintiffs, : Civil Action No.: 21-1453 (RC) : v. : Re Document Nos.: 71, 72 : DISTRICT OF COLUMBIA, : : Defendant. :

MEMORANDUM OPINION

GRANTING DEFENDANT’S MOTION FOR SANCTIONS AND FEES

I. INTRODUCTION

Plaintiffs J.T.F. and her mother, Ana Flores, (collectively, “Plaintiffs”) bring this action

against Defendant the District of Columbia, (“Defendant” or “the District”) alleging violations of

their rights under the Individuals with Disabilities Education Act (“IDEA”), 20 U.S.C. § 1400 et

seq.; Title VI of the Civil Rights Act of 1964, 42 U.S.C. § 2000d; the Equal Educational

Opportunities Act of 1974 (“EEOA”), 20 U.S.C. § 1701 et seq.; Section 504 of the Rehabilitation

Act of 1973, 29 U.S.C. § 794; and the Americans with Disabilities Act (“ADA”), 42 U.S.C.

§ 1201 et seq. Earlier in this litigation, this Court dismissed all claims contained in the Amended

Complaint except for the claims within Counts 1–18 under the EEOA and the Count 18 claim

under the IDEA.

Defendant now moves for attorney’s fees and to dismiss Plaintiffs’ remaining claims with

prejudice as a sanction for failing to comply with discovery obligations. For the reasons set forth

below, the Court grants Defendant’s motions. The Court dismisses Plaintiffs’ remaining claims

and will award Defendant fees in the amount of $15,670.58 for the services of Assistant Attorney General Tasha Hardy; $2,589.60 for the services of Section Chief Steven Rubenstein; and

$1,210.50 in fees for the services of Senior Assistant Attorney General Veronica Porter.

II. FACTUAL BACKGROUND

The Court assumes familiarity with the facts underlying this dispute, which are described

in the Court’s prior memorandum opinions. See Mem. Op. (“First Mem. Op.”), ECF No. 27;

Mem. Op. (“Second Mem. Op.”), ECF No. 40; Mem. Op. (“Third Mem. Op.”), ECF No. 54;

Mem. Op. (“Fourth Mem. Op.”), ECF No. 70. The facts are briefly recounted below.

Plaintiff Ana Flores brought this action on behalf of her daughter, J.T.F., who requires

specialized speech, language therapy, and occupational therapy services. Am. Compl. ¶¶ 17, 20,

ECF No. 2. J.T.F. and Ms. Flores are native Spanish speakers. Id. ¶¶ 17–18. Flores “reads and

writes only in Spanish, and understands little spoken English.” Id. ¶ 18. After allegedly

receiving an inadequate Individualized Education Plan (“IEP”) at Oyster-Adams Bilingual

School, the District of Columbia Public School System (“DCPS”) transferred J.T.F. to

MacFarland Middle School for the 2020–2021 school year. See id. ¶¶ 26–33, 72, 77–78.

Unhappy with the IEP and the resulting MacFarland placement, Flores filed a complaint

with the Office of Dispute Resolution (“ODR”) in the D.C. Office of the State Superintendent of

Education alleging that DCPS had violated the IDEA. Ex. 2 to Def.’s Mem. Supp. Mot. Dismiss

at 4, ECF No. 9-2 (“ODR Complaint”). In February 2021, an ODR Hearing Officer determined

that Flores was not entitled to relief on most of her claims. Am. Compl. ¶¶ 88, 90–110. On May

27, 2021, Plaintiffs filed suit in this Court, alleging that Defendant had violated the IDEA and

various other education and anti-discrimination statutes. Id. ¶¶ 111–33; see also Compl., ECF

No. 1. Early in this litigation, Defendant moved to dismiss Plaintiffs’ claims. Def.’s Mot.

Dismiss, ECF No. 9. On December 21, 2021, this Court dismissed each of the claims contained

2 in Plaintiffs’ Amended Complaint, save for claims within Counts 1–18 under the EEOA and the

claim within Count 18 under the IDEA. See First Mem. Op.; Second Mem. Op. at 7–8.

The parties then proceeded to discovery. The Court’s initial scheduling order required

the parties to conclude fact discovery by July 5, 2022. Third Mem. Op. at 2. Defendant served

Plaintiffs with interrogatories and requests for production—to be answered by June 30, 2022—

but Plaintiffs never responded. Id. at 2–3. This Court extended the close of discovery to

September 30, with Plaintiffs to respond to Defendant’s requests by August 15. Id. at 3.

Plaintiffs again missed the deadline, and this Court ordered Plaintiffs’ discovery responses by

October 24. Id. On October 21, Plaintiffs submitted partial and incomplete responses to

Defendant’s requests. Id. On November 1, Plaintiffs objected to Defendant’s interrogatories

because they were not translated into Spanish, an objection the Court later rejected as an invalid

and inadequate reason for not providing Defendant with responses. Id. at 8. (citing Calderon v.

Reederei Claus-Peter Offen GmbH & Co., No. 07-61022-CIV, 2008 WL 4194810, at *3 (S.D.

Fla. Sept. 11, 2008)).

On February 6, 2023, Defendant filed a motion seeking to compel Plaintiffs to provide

“full and complete responses to its discovery requests,” which the Court granted on August 28,

2023. Id. at 4 The Court ordered Plaintiffs to fully respond to Defendant’s discovery requests

within 30 days of the August 28 order and expressly warned Plaintiffs that noncompliance “will

have consequences up to and potentially even including dismissal.” Id. at 8.

In October 2023, the parties notified this Court that J.T.F. and her mother no longer

reside in the District of Columbia. See Pls.’ Notice of Change of Address, ECF No. 66.

Defendant also notified this Court that Plaintiffs had not provided any further responses to

Defendant’s interrogatories or requests for production of documents. See Joint Status Report

3 (“JSR”) at 1, ECF No. 55. Defendant then moved to dismiss Plaintiffs’ remaining IDEA and

EEOA claims on mootness grounds. See generally Def.’s Mem. in Supp. Def.’s Mot. Dismiss

(“Def.’s Second Mot. Dismiss”), ECF No. 56. Defendant moved in the alternative for the

sanction of dismissal under Federal Rule of Civil Procedure 37. See generally Def.’s Mem. in

Supp. Def.’s Mot. Sanctions (“Def.’s First Mot. Sanctions”), ECF No. 57.

This Court granted in part and denied in part Defendant’s motion to dismiss, dismissing

Plaintiffs’ IDEA claim as moot but allowing the Plaintiffs’ EEOA claim to proceed. See Fourth

Mem. Op. at 11, 14. Furthermore, this Court granted in part and denied in part Defendant’s

motion for sanctions, providing Plaintiffs with “one further extension” to fully respond to

Defendant’s discovery requests. Id. at 21. The Court expressly warned Plaintiffs that they must

“fully respond to the District’s discovery requests within thirty days of the date of [its] order,”

and that failure to so comply may result in sanctions, up to and including dismissal of their

remaining claims. Id. Plaintiffs have yet to provide Defendant with any response to the

interrogatories served on April 4, 2022—or any supplemental responsive documents—in

contravention of this Court’s order. See id.

Defendant now moves for attorney’s fees and for sanctions under Rule 37 of the Federal

Rules of Civil Procedure. Fed. R. Civ. P.

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