Morgan v. District of Columbia

CourtDistrict Court, District of Columbia
DecidedMarch 20, 2026
DocketCivil Action No. 2021-3040
StatusPublished

This text of Morgan v. District of Columbia (Morgan 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.

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Morgan v. District of Columbia, (D.D.C. 2026).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ____________________________________ ) EDWARD LEE MORGAN, SR., ) ) Plaintiff, ) ) v. ) Civil Action No. 21-3040 (RBW) ) DISTRICT OF COLUMBIA, et al., ) ) Defendants. ) )

MEMORANDUM OPINION

The plaintiff, Edward Lee Morgan, Sr., brings this civil action against the defendants, the

District of Columbia, Mayor Muriel Bowser; the District of Columbia Fire and Emergency

Medical Services Department (“FEMS”); and FEMS Chief John Donnelly. See Complaint for

Damages and for Declaratory and Injunctive Relief (“Compl.”) at 1, ECF No. 1. The plaintiff

alleges that he was terminated from his employment as an Emergency Medical Technician

(“EMT”) with FEMS in violation of his due process and equal protection rights under the

Fourteenth Amendment and in violation of the District of Columbia Administrative Procedure

Act (“DCAPA”), D.C. Code § 2-501, the District of Columbia Comprehensive Merit Personnel

Act of 1978 (“CMPA”), D.C. Code § 1-616.51, and the District of Columbia Human Rights Act

(“DCHRA”), D.C. Code § -1401.01. 1 See id. ¶ 1. Currently pending before the Court is the

defendants’ motion to dismiss. See Defendants’ Motion to Dismiss the Complaint

1 Although the plaintiff references the DCHRA in the Complaint’s preliminary statement, he does not refer to it again. The plaintiff also seeks relief “[p]ursuant to the Declaratory Judgment Act[,]” id. at 15, but the Declaratory Judgment Act, 28 U.S.C. § 2201, does not provide an independent cause of action. Jones v. U.S. Secret Service, 701 F. Supp. 3d 4, 14 n.1 (D.D.C. 2023). (“Defs.’ Mot.”) at 1, ECF No. 9. Upon careful consideration of the parties’ submissions, 2 the

Court concludes for the following reasons that it must (1) grant the defendants’ motion to

dismiss the claims against Mayor Bowser, FEMS Chief Donnelly, and the FEMS, (2) grant the

defendants’ motion to dismiss the plaintiff’s constitutional claims, (3) grant the defendants’

motion to dismiss the defendants’ CMPA claim, and (4) decline supplemental jurisdiction over

the plaintiff’s remaining DCAPA claims.

I. BACKGROUND

A. Factual Background

The following allegations are derived from the plaintiff’s Complaint, unless otherwise

specified. The plaintiff, an African American male, began working as an EMT with the FEMS

in 1987. See Compl. ¶¶ 12, 15. When the plaintiff began working as an EMT, all individuals in

the District of Columbia were required to have an active EMT certification in order to be

employed as an EMT. See id. ¶¶ 20–21. According to the Complaint, prior to July 1, 2009, all

EMTs in the District of Columbia were able to satisfy their certification requirements by passing

a certification or recertification examination administered by either the District of Columbia

Department of Health (“DOH”) or the National Registry of Emergency Medical Technicians

(“NREMT”). See id. ¶ 20. That changed on July 1, 2009, when the DOH stopped administering

EMT certification and recertification examinations. See id. Thereafter, in February 2010, the

FEMS issued Bulletin No. 83, “articulating its new policy requiring all [FEMS] employees to

complete the . . . []NREMT[] certification process[.]” Id. ¶ 21. After Bulletin No. 83 became

2 In addition to the filings already identified, the Court considered the following submissions in rendering its decision: (1) the Memorandum of Points and Authorities in Support of Defendants’ Motion to Dismiss the Complaint (“Defs.’ Mem.”), ECF No. 9; (2) the plaintiff’s Memorandum of Points and Authorities in Opposition to Defendant’s Motion to Dismiss the Complaint (“Pl.’s Opp’n”), ECF No. 11; and (2) the Reply in Support of Defendants’ Motion to Dismiss the Complaint (“Defs’ Reply”), ECF No. 12.

2 effective, the FEMS issued Agency General Order XXIX, GO-2006-14, which “exempted all

employee[s] hire[d] prior to January 1, 1987 from the NREMT certification requirement[.]” Id.

¶ 24.

The plaintiff’s certification lapsed on or about July 30, 2012, and he “failed to pass the

NREMT [recertification] examination between December 2010 and January 2012.” Id. ¶ 25.

According to the plaintiff, he was “never allowed to complete the remaining detailed process set

forth and mandated in Bulletin No. 83,” which “included . . . two additional NREMT

examination attempts[.]” Id. ¶ 26. Having failed to pass the NREMT recertification

examination, “[the p]laintiff was found incompetent and issued an Advance Written Notice of

Proposed Termination.” Id. ¶ 27. The plaintiff appealed the proposed termination by requesting

an administrative hearing, which was held in November 2012. See id. ¶ 28. At that hearing, the

plaintiff, representing himself, argued that “he personally knew of multiple other EMTs who

either failed NREMT certification more than six times[,] yet were allowed to return to the field,

or who were ostensibly exempted from the NREMT certification requirements altogether.” Id.

¶ 29. However, according to the plaintiff, “[t]he hearing officer refused to address the merits of

[his] discrimination claim[.]” 3 Id. ¶ 30. The plaintiff alleges that the administrative hearing

officer ultimately determined that he should be disciplined for not passing the recertification

exam, but “concluded that [the FEMS’] proposed penalty of termination for a one-time finding

of incompetence was disproportionate to the Douglas[v. Veterans Admin., 5 M.S.P.B. 313

(1981),] factors and the Agency’s own Table of Penalties.” Id. ¶ 31. Following the hearing, the

plaintiff was issued a Final Agency Decision that, according to the plaintiff, “purported to affirm

3 The Complaint does not explain the basis for the plaintiff’s “discrimination claim.”

3 [the hearing officer’s] conclusions while simultaneously upholding the proposed termination.”

Id. ¶ 32. The plaintiff’s employment was terminated on November 29, 2012. Id.

On December 28, 2012, the plaintiff, still representing himself, appealed the FEMS’ final

termination decision to the D.C. Office of Employee Appeals (“OEA”). Id. ¶ 35. The matter

was assigned to an administrative judge in February 2014, and the administrative judge issued an

Initial Decision on May 29, 2015. Id. According to the plaintiff, the administrative judge

determined that the FEMS’ decision to terminate him “was inconsistent with the [hearing

officer’s] findings,” id. ¶ 37, and “the guidelines imposed by the Table of Appropriate Penalties

. . . indicated [that] the appropriate penalty for a first[-time] offense of incompetence is a

suspension from five [ ] to fifteen [ ] days,” id. ¶ 38. After the administrative judge issued her

decision, the plaintiff claims that the OEA reversed the administrative judge’s termination,

substituted a fifteen-day suspension, and awarded the plaintiff “all back-pay and benefits lost as

a result of his removal almost three years prior.” Id. ¶ 39.

Subsequently, the FEMS “petitioned for review of [the] OEA’s decision, appealing only

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