King v. Raimondo

CourtDistrict Court, District of Columbia
DecidedJuly 15, 2025
DocketCivil Action No. 2024-1749
StatusPublished

This text of King v. Raimondo (King v. Raimondo) 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
King v. Raimondo, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

CALEB KING,

Plaintiff, Civil Action No. 24-1749 (SLS) v. Judge Sparkle L. Sooknanan

HOWARD LUTNICK,

Defendant.

MEMORANDUM OPINION

Caleb King, a resident of Arlington, Virginia, filed this lawsuit pro se against the Secretary

of the U.S. Department of Commerce alleging violations of Title VII of the Civil Rights Act of

1964, the Age Discrimination in Employment Act of 1967 (ADEA), and the Americans with

Disabilities Act of 1990 (ADA).1 Compl. at 3, ECF No. 1. Prior to his termination, Mr. King held

a one-year appointment as an Administrative Manager for the Department’s Decennial Census in

the Area Census Office in Hartford, Connecticut. See Defendant’s Motion to Dismiss (Def.’s Mot.)

at 2, ECF No. 8. His form Complaint identifies the alleged unlawful conduct as termination from

employment, the failure to accommodate a disability, unequal terms and conditions of

employment, and retaliation based on race, color, gender, religion, age, and disability. Compl. at

4. The Defendant has moved to dismiss under Federal Rules of Civil Procedure 12(b)(1), 12(b)(3),

1 The Defendant notes that Section 501 of the Rehabilitation Act of 1973, not the ADA, applies to a federal employee’s claim of disability discrimination and “incorporates the standards applied under the ADA.” Def.’s Mot. at 1, n.1 (citing Ward v. McDonald, 762 F.3d 24, 28 (D.C. Cir. 2014). Because “the analysis of the legal issues is identical in all relevant respects,” id., the Court construes the Plaintiff’s ADA claim as one under the Rehabilitation Act. and 12(b)(6). See Def.’s Mot. The Court grants the motion in part and transfers the case to the

United States District Court for the District of Connecticut.

In considering a Rule 12(b)(3) motion for improper venue, courts “must accept all well-

pleaded factual allegations as true and draw all reasonable inferences in favor of the plaintiff.”

Herbert v. Sebelius, 925 F. Supp. 2d 13, 17 (D.D.C. 2013) (citations omitted). But courts need not

accept as true inferences that are unsupported by the factual allegations, and it may consider

material outside of the pleadings. Id. When venue is challenged, “the burden remains on the

plaintiff to establish that venue is proper[.]” Slaby v. Holder, 901 F. Supp. 2d 129, 132 (D.D.C.

2012). To prevail on a Rule 12(b)(3) motion, the defendant must present facts that will defeat the

plaintiff’s assertion of venue. Herbert, 925 F. Supp. 2d at 17.

Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e et seq., “provides the exclusive

judicial remedy for claims of discrimination in federal employment,” Brown v. GSA, 425 U.S. 820,

835 (1976), and it governs “[a]ll personnel actions affecting employees or applicants for

employment,” 42 U.S.C. § 2000e-16(a). The ADEA “provides the exclusive remedy for a federal

employee who claims age discrimination,” Chennareddy v. Bowsher, 935 F.2d 315, 318 (D.C. Cir.

1991) (citations omitted), and the Rehabilitation Act provides the “exclusive remedy” for a federal

employee claiming disability discrimination, Rand v. Geithner, 609 F. Supp. 2d 97, 100 (D.D.C.

2009) (citing 29 U.S.C. § 791).

In Title VII and Rehabilitation Act cases, venue is not determined under the general venue

statute, 28 U.SC. § 1391. See, e.g., Taylor v. Shinseki, 13 F. Supp. 3d 81, 86 (D.D.C. 2014) (noting

that the general venue provision does not govern in Title VII cases); Troster v. Garland, No. 20-

cv-3584, 2021 WL 5865447, at *3 (D.D.C. Dec. 10, 2021) (same in Rehabilitation Act cases).

Rather, Title VII’s special venue provision governs. See Daniels v. Wilkie, No. 17-cv-1543, 2018

2 WL 2324085, at *3 (D.D.C. May 22, 2018) (citation omitted). Under that provision, venue is

proper

[1] in any judicial district in the State in which the unlawful employment practice is alleged to have been committed, [2] in the judicial district in which the employment records relevant to such practice are maintained and administered, or [3] in the judicial district in which the aggrieved person would have worked but for the alleged unlawful employment practice, [4] but if the respondent is not found within any such district, such an action may be brought within the judicial district in which the respondent has his principal office.

42 U.S.C. § 2000e-5(f)(3). “Venue is proper if at least one of the section 2000e-5(f)(3) prongs is

satisfied.” Alessa v. Harker, No. 20-cv-1320, 2021 WL 5911180, at *3 (D.D.C. Mar. 31, 2021)

(citations omitted).

Mr. King’s filings contain no facts plausibly establishing the District of Columbia as the

proper venue under Section 2000e-5(f)(3). None of the relevant events occurred in the District of

Columbia; the relevant record does not appear to be maintained in the District of Columbia; and

nothing suggests that Mr. King would have worked in the District of Columbia but for the

Defendant’s alleged unlawful employment practices. See 42 U.S.C. § 2000e-5(f)(3). In fact, the

Defendant attests that the Census Office that employed Mr. King “reported to the New York

Regional Census Center,” and that Mr. King’s “employment records are stored in New York[.]”

Decl. of Dawn Washington ¶¶ 5-6, ECF No. 11-1. And Mr. King’s veiled references to contacts

he may have had with the Census Bureau’s EEO Office and the Office of Personnel Management

in Washington, D.C., see Plaintiff’s Opposition at 6, ECF No. 10, are irrelevant. See Herbert, 925

F. Supp. 2d at 20 (“Courts in this district have rejected the argument that the location where

plaintiff’s EEO complaints were initiated and processed provides a basis for venue[.]” (cleaned

up)). Venue in this judicial district is thus improper for Mr. King’s Title VII and Rehabilitation

Act claims.

3 Venue in ADEA cases is determined under the general venue provision. In re O’Leska,

No. 00-5339, 2000 WL 1946653, at *1 (D.C. Cir. Dec. 7, 2000) (per curiam) (citing Rebar v.

Marsh, 959 F.2d 216 (11th Cir. 1992)). Thus, an ADEA claim “against an officer or employee of

the United States acting in his official capacity may be brought where (1) a defendant in the action

resides, (2) a substantial part of the events giving rise to the claim arose, or (3) the plaintiff resides.”

Id. (citing 28 U.S.C. § 1391(e)). “[T]he plaintiff may choose from among [these] three alternative

forums where venue is proper.” Lamont v.

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Brown v. General Services Administration
425 U.S. 820 (Supreme Court, 1976)
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John Sinclair v. Richard G. Kleindienst
711 F.2d 291 (D.C. Circuit, 1983)
Rand v. Geithner
609 F. Supp. 2d 97 (District of Columbia, 2009)
James v. VERIZON SERVICES CORP.
639 F. Supp. 2d 9 (District of Columbia, 2009)
Herbert v. Sebelius
925 F. Supp. 2d 13 (District of Columbia, 2013)
Slaby v. Holder
901 F. Supp. 2d 129 (District of Columbia, 2012)
Ella Ward v. Robert A. McDonald
762 F.3d 24 (D.C. Circuit, 2014)
Taylor v. Shinseki
13 F. Supp. 3d 81 (D.C. Circuit, 2014)

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