Nwosu v. Bolduc

CourtDistrict Court, District of Columbia
DecidedMarch 10, 2024
DocketCivil Action No. 2023-3841
StatusPublished

This text of Nwosu v. Bolduc (Nwosu v. Bolduc) 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
Nwosu v. Bolduc, (D.D.C. 2024).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

ADAEZE NWOSU,

Plaintiff,

v. No. 23-cv-3841 (DLF)

MAGDALIT BOLDUC, et al.,

Defendants.

ORDER

Adaeze Nwosu visited Israel and Palestine on a church trip. Unhappy with her experience,

she sued Father Luc Vaillant, Sister Magdalit Bolduc, and the Archdiocese of Denver in federal

court. All three defendants move to dismiss Nwosu’s suit for lack of personal jurisdiction. Dkt. 8.

For the reasons that follow, the Court will grant their motion.

Lawsuits require personal jurisdiction. Mallory v. Norfolk S. Ry. Co., 600 U.S. 122, 128–

29 (2023). In this case, personal jurisdiction over the defendants turns on the District of

Columbia’s long-arm statute and the Fourteenth Amendment’s Due Process Clause. Fed. R. Civ.

P. 4(k)(1)(A); GTE New Media Servs. Inc. v. BellSouth Corp., 199 F.3d 1343, 1347 (D.C. Cir.

2000).

Under D.C. law, a court “may exercise personal jurisdiction over a person, who acts

directly or by an agent, as to a claim for relief arising from the person’s—(1) transacting any

business in the District of Columbia; (2) contracting to supply services in the District of Columbia;

(3) causing tortious injury in the District of Columbia by an act or omission in the District of

Columbia; (4) causing tortious injury in the District of Columbia by an act or omission outside the

District of Columbia if he regularly does or solicits business, engages in any other persistent course of conduct, or derives substantial revenue from goods used or consumed, or services rendered, in

the District of Columbia; [or] (5) having an interest in, using, or possessing real property in the

District of Columbia.” D.C. Code § 13-423(a). Under the Constitution, jurisdiction must also

comport with traditional principles of due process. Phillips Petroleum Co. v. Shutts, 472 U.S. 797,

807 (1985); Mallory, 600 U.S. at 128–29.

Nwosu falters at the first step: D.C. law. Nwosu, who lives in Maryland, says that Sister

Bolduc and Father Vaillant, who live in Colorado and work for the Archdiocese of Denver,

harassed and discriminated against her on a “13-day religious pilgrimage [in] the Holy Land.”

Compl. at 4, Dkt. 1. Those claims do not stem from business transacted, services supplied, or real

property held in the District. Cf. D.C. Code § 13-423(a)(1)–(2), (5). They do not imply that the

defendants injured Nwosu in the District by acting or failing to act in the District. Id. § 13-

423(a)(3). And they do not suggest that any defendant “regularly” engages in “conduct” touching

the District, see Shaheen v. Smith, 994 F. Supp. 2d 77, 84 (D.D.C. 2013), or that Nwosu faced

“tortious injury in” the District, D.C. Code § 13-423(a)(4). Cf. Helmer v. Doletskaya, 393 F.3d

201, 209 (D.C. Cir. 2004) (holding that injury did not “occur” in D.C. when injurious acts did not

take place in D.C. and injured party did not reside in D.C.). It follows that Nwosu cannot establish

personal jurisdiction under D.C. law and that this Court cannot hear her case.

Nwosu emphasizes that the Archdiocese’s “administration is overseen by the United States

Conference of Catholic Bishops . . . in Washington, DC.” Compl. at 4. Even so, the Conference’s

activities in the District do not give rise to personal jurisdiction over the defendants. For one thing,

Nwosu’s “claim[s] for relief” do not “aris[e] from” the Conference’s oversight activities. D.C.

Code § 13-423(a). Claims arise from conduct when they bear a “discernible relationship” to that

conduct, Shoppers Food Warehouse v. Moreno, 746 A.2d 320, 335–36 (D.C. 2000), and Nwosu

2 pleads no facts suggesting that Conference oversight had anything to do with her experience during

her travels. Just as importantly, even if Conference oversight made the Conference liable for

Nwosu’s injuries, it would not show that the defendants ever acted in the District of Columbia. Cf.

Shapiro, Lifschitz & Schram, P.C. v. Hazard, 24 F. Supp. 2d 66, 70 (D.D.C. 1998) (“Ordinarily, a

defendant corporation’s contacts with a forum may not be attributed to shareholders, affiliated

corporations, or other parties.”). The Court’s personal-jurisdiction inquiry thus begins and ends at

the first step, and the Court concludes that it lacks personal jurisdiction over the defendants.

Finally, the Court will not transfer Nwosu’s action “in the interest of justice” and will deny

her leave to file an amended complaint. 28 U.S.C. § 1631. As for transfer, Nwosu has not

requested it or explained why it is warranted. Cf. Does 1–144 v. Chiquita Brands Int’l, Inc., 285

F. Supp. 3d 228, 233 (D.D.C. 2018) (“The party requesting transfer bears the burden of

establishing” that transfer would be in the interest of justice.). In any event, dismissing an action

rather than transferring it is appropriate when “it appears that [a] complaint in its current form

would likely face dismissal . . . for failure to state a claim.” Roman-Salgado v. Holder, 730 F.

Supp. 2d 126, 131 (D.D.C. 2010) (citing cases); accord Naartex Consulting Corp. v. Watt, 722

F.2d 779, 785 (D.C. Cir. 1983). Nwosu’s complaint, which (among other things) seeks damages

for breach of contract based on her contention that the defendants violated the terms of the Catholic

Catechism, fits the bill.1

1 In particular, Nwosu’s breach-of-Catechism claim likely fails because it raises “ecclesiastical questions” federal courts cannot answer under the First Amendment. Presbyterian Church in U.S. v. Mary Elizabeth Blue Hull Memorial Presbyterian Church, 393 U.S. 440, 447 (1969). Her claim for defamation likely fails because she does not plead defamation per se or show that the defendants’ remarks caused her “economic or pecuniary” losses. Restatement (Second) of Torts § 575 cmt. b (1977). Her remaining tort claims for loss of privacy and/or intentional infliction of emotional distress likely fail because she does not plead “highly offensive” or “outrageous” conduct. Id. §§ 46, 652D, 652E. Her age discrimination claim likely fails for failure to exhaust administrative remedies, 42 U.S.C. § 6104(f), and because the Age 3 As for Nwosu’s Motions for Leave to Amend, Dkts. 15, 17, the Court will deny them as

futile, see, e.g., James Madison Ltd. ex rel. Hecht v. Ludwig, 82 F.3d 1085, 1099 (D.C. Cir. 1996).

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Related

Phillips Petroleum Co. v. Shutts
472 U.S. 797 (Supreme Court, 1985)
Gebser v. Lago Vista Independent School District
524 U.S. 274 (Supreme Court, 1998)
General Dynamics Land Systems, Inc. v. Cline
540 U.S. 581 (Supreme Court, 2004)
GTE New Media Services Inc. v. BellSouth Corp.
199 F.3d 1343 (D.C. Circuit, 2000)
Helmer, John v. Doletskaya, Elena
393 F.3d 201 (D.C. Circuit, 2004)
Shoppers Food Warehouse v. Moreno
746 A.2d 320 (District of Columbia Court of Appeals, 2000)
Mwabira-Simera v. Howard University
692 F. Supp. 2d 65 (District of Columbia, 2010)
Roman-Salgado v. Holder
730 F. Supp. 2d 126 (District of Columbia, 2010)
Shapiro, Lifschitz & Schram, P.C. v. Hazard
24 F. Supp. 2d 66 (District of Columbia, 1998)
Shaheen v. Smith
994 F. Supp. 2d 77 (District of Columbia, 2013)
S. Baxter Jones v. City of Detroit, Mich.
20 F.4th 1117 (Sixth Circuit, 2021)
Doe v. Chiquita Brands Int'l, Inc.
285 F. Supp. 3d 228 (D.C. Circuit, 2018)

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