Valibeigi v. District of Columbia

CourtDistrict Court, District of Columbia
DecidedSeptember 27, 2024
DocketCivil Action No. 2022-3149
StatusPublished

This text of Valibeigi v. District of Columbia (Valibeigi 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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Valibeigi v. District of Columbia, (D.D.C. 2024).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

MEHRDAD VALIBEIGI,

Plaintiff,

v. Civil Action No. 22-3149 (TJK) DISTRICT OF COLUMBIA,

Defendant.

MEMORANDUM OPINION

Mehrdad Valibeigi alleges that, over the last few years, the District of Columbia sued him

and his corporations and obtained civil judgments against them for failing to maintain three apart-

ment buildings in compliance with the District’s housing laws and regulations. Proceeding pro se

here, he alleges that, in doing so, the District violated his rights under the First, Fourth, Fifth, and

Fourteenth Amendments. The District moves to dismiss, arguing that Valibeigi’s claims are time-

barred and that he has failed to plausibly allege any constitutional violations or municipal liability.

The Court agrees with the latter two reasons and will dismiss the complaint.

I. Background

In his Amended Complaint, Valibeigi alleges that he owned three residential apartment

complexes in the District—Bennington Apartments, Astor Place Apartments, and Westwood.

ECF No. 4 ¶¶ 5, 7–10. But “as the result of increased gang activities around [those] properties,”

the three complexes developed “physical and financial management challenges” that led to various

“housing code violations verified by” District officials. Id. ¶ 7. Valibeigi says that those violations

eventually prompted the District, through the Office of the Attorney General (“OAG”), to sue him

and his corporations under the Consumer Protection Procedures Act (“CPPA”), D.C. Code § 28- 3901 et seq., and the Tenant Receivership Act (“TRA”), D.C. Code § 42-3651.01 et seq. ECF No.

4 ¶¶ 7–10.

While those lawsuits were pending, Valibeigi tried to sell the Bennington and Astor prop-

erties, but each sale fell through. ECF No. 4 ¶¶ 10–17. He also tried to renovate the Bennington

property, but the renovation company backed out of the contract in the middle of these legal dis-

putes, supposedly because of false statements made by an attorney for the OAG. Id. ¶ 11. Even-

tually, Valibeigi claims that he and his companies were forced into bankruptcy and had to sell the

three apartment complexes. Id. ¶¶ 14–19. Thus, he alleges that he has suffered various “financial,

emotional and reputational harms” from the District’s actions. Id. at 3.

Valibeigi sued the District in October 2022 and amended his complaint two months later.

See ECF Nos. 1, 4. He asserts that the District violated the First, Fourth, Fifth, and Fourteenth

Amendments by discriminating against him, “Torpedo[ing] the Sale of [his] Properties,” and

“Rel[ying] on Misinformation and False Statements.” ECF No. 4 ¶¶ 33–47. As to the alleged

discrimination, he claims that the District engaged in selective enforcement through (1) treating

him and other small, private landlords differently than the District of Columbia Housing Authority

(“DCHA”) by suing them under the CPPA and TRA, rather than the Nuisance Abatement Act

(“NAA”); and (2) targeting properties for enforcement in or near less well-off areas of the District.

See id. at 2, ¶¶ 33–38. Valibeigi alleges no statutory basis for these claims, but the Court liberally

construes his pro se complaint as brought under 42 U.S.C. § 1983.

The District moves to dismiss for failure to state a claim under Federal Rule of Civil Pro-

cedure 12(b)(6).

II. Legal Standards

“To survive a motion to dismiss under Rule 12(b)(6), ‘a complaint must contain sufficient

factual matter, accepted as true, to state a claim to relief that is plausible on its face.’” Frederick

2 Douglass Found., Inc. v. District of Columbia, 82 F.4th 1122, 1135 (D.C. Cir. 2023) (quoting

Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009)). For a complaint to be facially plausible, “it must

‘plead[] factual content that allows the court to draw the reasonable inference that the defendant is

liable for the misconduct alleged.’” Hettinga v. United States, 677 F.3d 471, 476 (D.C. Cir. 2012)

(quoting Iqbal, 556 U.S. at 678). Additionally, when reviewing a motion to dismiss for failure to

state a claim, “the Court must construe the complaint ‘in favor of the plaintiff, who must be granted

the benefit of all inferences that can be derived from the facts alleged.’” Id. (Schuler v. United

States, 617 F.2d 605, 608 (D.C. Cir. 1979)). Even so, the complaint must be “enough to raise a

right to relief above the speculative level.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007).

“[M]ere conclusory statements” cannot establish a claim plausible on its face. Iqbal, 556 U.S. at

678.

Additionally, when a complaint is filed pro se, it “must be held to less stringent standards

than formal pleadings drafted by lawyers.” Erickson v. Pardus, 551 U.S. 89, 94 (2007) (quoting

Estelle v. Gamble, 429 U.S. 97, 106 (1976)); Cf. Fed. R. Civ. P. 8(e) (“Pleadings must be construed

so as to do justice.”). But “this benefit is not [] a license to ignore the Federal Rules of Civil

Procedure.” Fontaine v. JPMorgan Chase Bank, N.A., 42 F. Supp. 3d 102, 106 (D.D.C. 2014)

(alteration in original) (quoting Sturdza v. United Arab Emirates, 658 F. Supp. 2d 135, 137 (D.D.C.

2009)).

III. Analysis

Under 42 U.S.C. § 1983, a plaintiff may sue any “person” who, under color of law, has

“subject[ed]” the plaintiff “to the deprivation of any rights, privileges, or immunities secured by

the Constitution and laws” of the United States. For purposes of this statute, a municipality or

local government qualifies as a “person.” See Monell v. Dep’t of Soc. Servs., 436 U.S. 658, 692

(1978). But municipalities “are not liable for injuries inflicted solely by their employees or

3 agents.” Frederick Douglass Found., Inc., 82 F.4th at 1136. Nor can they “be held liable under

§ 1983 on a respondeat superior theory.” Monell, 436 U.S. at 691. Instead, for a municipal gov-

ernment to be liable under § 1983, the government must be the ‘moving force’ behind the viola-

tion,” and the violation must be “the result of an official custom or policy.” Frederick Douglass

Found., Inc., 82 F.4th at 1136 (quoting Monell, 436 U.S. at 694).

“Accordingly, in considering whether a plaintiff has stated a claim for municipal liability”

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