Tillmon v. Washington Metropolitan Area Transit Authority

CourtDistrict Court, District of Columbia
DecidedMarch 18, 2025
DocketCivil Action No. 2024-1176
StatusPublished

This text of Tillmon v. Washington Metropolitan Area Transit Authority (Tillmon v. Washington Metropolitan Area Transit Authority) 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
Tillmon v. Washington Metropolitan Area Transit Authority, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

ANTOINE D. TILLMON,

Plaintiff,

v. No. 24-cv-01176 (DLF) WASHINGTON METROPOLITAN AREA TRANSIT AUTHORITY,

Defendant.

MEMORANDUM OPINION AND ORDER

Antoine Tillmon brings this action pro se against the Washington Metropolitan Area

Transit Authority (WMATA) under the Americans with Disabilities Act (ADA), 42 U.S.C.

§§ 12101 et seq., and the Family and Medical Leave Act (FMLA), 29 U.S.C. §§ 2601 et seq. Am.

Compl., Dkt. 8. He alleges that WMATA took various retaliatory and discriminatory actions in

response to him exercising his FMLA rights. Before the Court is WMATA’s Motion to Dismiss

this action under Rule 12(b)(1) of the Federal Rules of Civil Procedure or, in the alternative, under

Rule 12(b)(6). 1 Dkt. 17. For the reasons that follow, the Court will grant WMATA’s motion.

I. BACKGROUND

Tillmon has been employed by WMATA since at least 2017, first as a train operator, Am.

Compl. ¶ 4, and later as a bus operator, id. ¶ 1. Tillmon first “applied and was approved for

FMLA” in 2017. Id. ¶ 4. In June 2023, “due to the overwhelming stress and demand” of the job,

1 Although WMATA styles its motion as one to dismiss under Rule 12(b)(1) for lack of jurisdiction, it argues in the alternative that Tillmon has failed to allege a family-care-related medical leave claim under the FMLA, Mot. to Dismiss, at 5 n.1, Dkt. 17. Because the Court will construe Tillmon’s pro se complaint liberally to assert a family-care-related medical leave claim, it will also address WMATA’s alternate argument under Rule 12(b)(6). he sought to be approved for FMLA a second time. Id. By July 17, Tillmon was notified that “his

FMLA was approved for taking a full day off work twice per month per [his] doctor’s request for

[Tillmon’s] mental health condition.” Id. ¶ 6.

Tilllmon used his approved two monthly days off throughout the fall of 2023. Id. ¶¶ 7–24.

In October, Tillmon called in “to be absent for Family Sick” because his “son was involved in a

car accident.” Id. ¶ 14. He ended up taking “five days [off] to care for his son.” Id. When Tillmon

returned to work, WMATA required him to undergo drug and alcohol testing. Id. ¶ 15.

WMATA later placed Tillmon on administrative leave while they investigated an incident

related to improper operation of a train. Id. ¶¶ 25–27. Based on the results of that investigation,

Tillmon was “disqualified and terminated as a Train Operator,” and was placed on leave without

pay. Id. ¶ 28. Tillmon maintains that the findings in the investigation report are “erroneous.” Id..

In February 2024, he returned to work for WMATA as a bus operator. Id. ¶ 32. Tillmon alleges

that WMATA continued to discriminate against him because of his FMLA accommodation after

he resumed work as a bus operator. Id. ¶¶ 33–39.

Tillmon initiated this lawsuit on April 23, 2024, and filed his amended complaint on May

14, 2024. Dkts. 1, 8. He alleges that he was subject to “unwarranted scrutiny, disciplinary

measures, and retaliatory practices” because of “his requests for medical leave and

accommodations.” Opp’n, at 1, Dkt. 19. WMATA missed the answer deadline, and Tillmon

moved several times for entry of default judgment. Dkts. 10, 11, 12. The Court initially entered

default judgment, but the default was ultimately excused. Dkt. 13; Minute Order of June 13, 2024.

WMATA then filed this motion to dismiss for lack of jurisdiction, or in the alternative, for failure

to state a claim. Dkt. 17.

2 II. LEGAL STANDARDS

Under Federal Rule of Civil Procedure 12(b)(1), a defendant may move to dismiss an action

for lack of subject-matter jurisdiction. Fed. R. Civ. P. 12(b)(1). Because “[s]overeign immunity

is jurisdictional in nature,” FDIC v. Meyer, 510 U.S. 471, 475 (1994), claims barred by the United

States’ sovereign immunity are “subject to dismissal under Rule 12(b)(1),” Clayton v. District of

Columbia, 931 F. Supp. 2d 192, 200 (D.D.C. 2013). When reviewing a motion to dismiss for lack

of jurisdiction, the court must “assume the truth of all material factual allegations in the complaint

and construe the complaint liberally.” Am. Nat. Ins. Co. v. FDIC, 642 F.3d 1137, 1139 (D.C. Cir.

2011) (internal quotation marks omitted). At the same time, plaintiffs bear the burden of

establishing subject-matter jurisdiction, see Arpaio v. Obama, 797 F.3d 11, 19 (D.C. Cir. 2015),

and courts must raise obstacles to their jurisdiction sua sponte, see Fort Bend Cty. v. Davis, 587

U.S. 541, 548 (2019). “[W]hile complaints filed by pro se litigants are held to a less stringent

standard than those applied to formal pleadings drafted by lawyers, even a pro se plaintiff bears

the burden of establishing that the Court has subject matter jurisdiction.” Newby v. Obama, 681

F. Supp. 2d 53, 55 (D.D.C. 2010) (cleaned up).

Rule 12(b)(6) of the Federal Rules of Civil Procedure allows a defendant to move to

dismiss a complaint for failure to state a claim upon which relief can be granted. Fed. R. Civ. P.

12(b)(6). To survive a Rule 12(b)(6) motion, a complaint must contain factual matter sufficient to

“state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570

(2007). A facially plausible claim is one that “allows the court to draw the reasonable inference

that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678

(2009). This standard does not amount to a specific probability requirement, but it does require

“more than a sheer possibility that a defendant has acted unlawfully.” Id.; see also Twombly, 550

3 U.S. at 555 (“Factual allegations must be enough to raise a right to relief above the speculative

level.”). A complaint need not contain “detailed factual allegations,” Iqbal, 556 U.S. at 678, but

alleging facts that are “merely consistent with a defendant’s liability . . . stops short of the line

between possibility and plausibility,” id. (internal quotation marks omitted).

III. ANALYSIS

WMATA moves to dismiss under Rule 12(b)(1) for lack of subject matter jurisdiction.

Dkt. 17. It claims that sovereign immunity generally bars Tillmon’s ADA and FMLA claims.

Though WMATA acknowledges that States cannot claim sovereign immunity for FMLA family-

care claims, it argues that Tillmon has not properly raised one, Mot. to Dismiss at 4–5, which the

Court will address under Rule 12(b)(6).

A. Rule 12(b)(1)

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