Smith v. Camden Development Inc.

CourtDistrict Court, District of Columbia
DecidedJune 23, 2026
DocketCivil Action No. 2024-0428
StatusPublished

This text of Smith v. Camden Development Inc. (Smith v. Camden Development Inc.) 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
Smith v. Camden Development Inc., (D.D.C. 2026).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

KAYLA SMITH,

Plaintiff,

v. Civil Action No. 24-428 (TJK)

CAMDEN DEVELOPMENT INC. et al.,

Defendants.

MEMORANDUM ORDER

Kayla Smith sued Defendants Camden Development Inc. and Jose Mancilla in February

2024, bringing claims for sexual harassment under both federal and District of Columbia law, as

well as for common-law torts. Her claims focus on Camden’s “Hug Life” policy, which she alleges

caused a hostile work environment and facilitated her sexual assault at the hands of Mancilla.

Camden moved to dismiss and then for judgment on the pleadings, and the Court resolved all the

claims against it in its favor, leaving one count of common-law negligence remaining against it.

Mancilla—whom Smith did not successfully serve until 2025—now moves to dismiss the two

claims against him: sexual harassment and battery, each brought under District of Columbia law.

He argues that the Court lacks subject-matter jurisdiction over the claims against him because no

federal claims remain in the case. For the reasons explained below, the Court has supplemental

jurisdiction over the claims against Mancilla and will exercise its discretion to maintain that juris-

diction, even though no federal claims remain. Thus, it will deny his motion.

I. Background

Smith alleges that she began working as a leasing consultant at Camden, a real estate man-

agement company, in 2021. ECF No. 1 ¶ 10. During her orientation, Smith was required to watch videos setting out Camden’s so-called “Hug Life” policy, that “promoted [Camden’s] hugging

policy as its workplace culture.” Id. ¶ 25. One such “Hug Life” video stated that at Camden

“hugging is simply a part of who we are,” and “now that you’re a part of the Camden Family, we

look forward to hugging you too.” Id. ¶ 26. Smith alleges that she was sexually assaulted at work

by Mancilla because of the policy. She claims that Mancilla, a maintenance manager at Camden,

asked Smith for a hug while the two were alone in one of Camden’s rental units in March 2022.

Id. ¶¶ 43, 48. Because of Camden’s alleged “workplace hugging policy and culture,” Smith was

“accustomed to hugging coworkers and managers” and agreed to hug Mancilla. Id. ¶ 49. But then,

she alleges, Mancilla refused to end the hug and began sexually assaulting her. Id. ¶¶ 50–67.

Smith sued Camden and Mancilla in February 2024. ECF No. 1. She asserted eight counts.

Counts I through III are sexual harassment claims against Camden under Title VII and the District

of Columbia Human Rights Act (“DCHRA”) based on Camden’s alleged “Hug Life” policy. Id.

¶¶ 82–100. Count IV is a sexual harassment claim against both Defendants under the DCHRA

based on Mancilla’s alleged assault. Id. ¶¶ 101–107. Count V and VI are negligence and battery

claims against Camden stemming from the sexual assault, Count VII is a battery claim against

Mancilla based on the same, and Count VIII is a constructive discharge claim against Camden. Id.

¶¶ 108–121.

Smith purportedly served both Defendants soon after filing suit, see ECF Nos. 3, 4, and

Camden then moved to dismiss Counts I through VI for failure to state a claim under Federal Rule

of Civil Procedure 12(b)(6). ECF No. 6. Mancilla, for his part, did not timely respond to the

Complaint. The Court granted Camden’s Motion to Dismiss in part and dismissed Counts I, II,

III, and VI, and dismissed Count IV as to Camden. Minute Order of Dec. 16, 2024; ECF No. 14.

Proceeding without Mancilla, the Court then held an initial scheduling conference with Smith and

2 Camden in February 2025 and entered a scheduling order as to discovery on Counts V and VIII,

the sole remaining claims against Camden. See ECF No. 20. Camden then moved for judgment

on the pleadings as to Count VIII, which the Court granted, leaving only Count V, the negligence

claim, remaining against Camden. ECF No. 21; Minute Order of May 1, 2025.

In October 2025, while Smith and Camden were engaged in discovery, Mancilla appeared

for the first time. ECF No. 26. He moved to dismiss under Federal Rule of Civil Procedure

12(b)(5), arguing that Smith failed to properly serve him. ECF No. 27. The Court agreed that

Smith had not met her burden to show that she properly served Manilla but denied Mancilla’s

motion to dismiss. ECF No. 31. Instead, the Court allowed Smith more time to serve Mancilla

properly, which she did in December 2025. Id.; ECF No. 36.

Mancilla now moves to dismiss again, this time under Rule 12(b)(1). ECF No. 45. He

argues that this Court lacks subject-matter jurisdiction over Smith’s claims against him because

the Court’s dismissal of all federal claims extinguished the Court’s supplemental jurisdiction over

the two claims against him—Counts IV and Count VII—both of which are based on District of

Columbia law. See id. In response, Smith argues that the Court should exercise its discretion to

retain supplemental jurisdiction over these claims. ECF No. 46.

II. Legal Standard

“Federal [district] courts are courts of limited jurisdiction,” possessing “only that power

authorized by Constitution and statute, which is not to be expanded by judicial decree.” Kokkonen

v. Guardian Life Ins. Co. of Am., 511 U.S. 375, 377 (1994) (citations omitted). Under Rule

12(b)(1), the plaintiff has the burden to establish the Court’s subject-matter jurisdiction. Daim-

lerChrysler Corp. v. Cuno, 547 U.S. 332, 342 (2006).

When a district court has “original jurisdiction” over a claim, it also has “supplemental

jurisdiction over all other claims that are so related to claims in the action within such original

3 jurisdiction that they form part of the same” Article III “case or controversy.” 28 U.S.C. § 1367(a).

In simpler terms, “a federal court often has the power to decide state-law questions” if the com-

plaint brings a sufficiently related federal-law claim. Royal Canin U.S.A., Inc. v. Wullschleger,

604 U.S. 22, 27 (2025). Still, “courts may decline to exercise supplemental jurisdiction over” a

state-law claim even when they could keep the claim under the jurisdictional grant within

§ 1367(a). See 28 U.S.C. § 1367(c). A “district court’s decision whether to exercise that jurisdic-

tion after dismissing every claim over which it had original jurisdiction is purely discretionary.”

Carlsbad Tech., Inc. v. HIF Bio, Inc., 556 U.S. 635, 639 (2009). And this question “is not a juris-

dictional matter,” but rests in the discretion of the court. Id. at 640 (quoting 16 J. Moore et al.,

Moore’s Federal Practice § 106.05[4], pp. 106–27 (3d ed. 2009)). The factors courts consider in

such cases are “judicial economy, convenience, fairness, and comity.” Edmondson & Gallagher

v. Alban Towers Tenants Ass’n, 48 F.3d 1260, 1266 (D.C.

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Related

Kokkonen v. Guardian Life Insurance Co. of America
511 U.S. 375 (Supreme Court, 1994)
DaimlerChrysler Corp. v. Cuno
547 U.S. 332 (Supreme Court, 2006)
Carlsbad Technology, Inc. v. HIF Bio, Inc.
556 U.S. 635 (Supreme Court, 2009)
Shekoyan, Vladmir v. Sibley Intl
409 F.3d 414 (D.C. Circuit, 2005)
Royal Canin U. S. A. v. Wullschleger
604 U.S. 22 (Supreme Court, 2025)

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