Ward v. Mayorkas

District Court, District of Columbia·Decided September 11, 2026·No. Civil Action No. 2023-0813·Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

)

KATHERINE WARD, )

)

Plaintiff, )

)

v. ) Civil Action No. 23-813 (RBW)

)

MARKWAYNE MULLIN, 1 in his official ) capacity as the Secretary of the ) Department of Homeland Security, )

)

Defendant. )

)

MEMORANDUM OPINION

The plaintiff, Katherine Ward, brings this civil action against the defendant, Markwayne Mullin, in his official capacity as the Secretary of the Department of Homeland Security (“DHS”), alleging “unlawful employment discrimination on the basis of sex, disability, reprisal, hostile work environment[,] and interference with statutorily protected rights in violation of Title VII of the Civil Rights Act of 1964,” 42 U.S.C. §§ 2000e–2000e-16(a), and § 501 of the Rehabilitation Act (“the Act”), 29 U.S.C. § 791. See First Amended Complaint (“Am. Compl.”) at 1, ECF No. 22. Currently pending before the Court is the defendant’s motion to dismiss pursuant to Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6). See generally Defendant’s Motion to Dismiss and Memorandum in Support Thereof (“Def.’s Mem.”), ECF No. 26. Upon careful consideration of the parties’ submissions, 2 the Court concludes for the following reasons

1 Markwayne Mullin is the current United States Secretary of Homeland Security and is therefore substituted for Alejandro Mayorkas and Kristi L. Noem as the proper party defendant pursuant to Federal Rule of Civil Procedure 25(d). 2 In addition to the filings already identified, the Court considered the following submissions in rendering its decision: (1) the Complaint, (“Original Compl.” or “Compl.”), ECF No. 1; (2) Compl., Exhibit (“Ex.”) 20 (“Records Reflecting Pl.’s Medical Ailments”), ECF No. 1-1; (3) the Transcript of Motion Hearing Before the Honorable Reggie B. Walton (Continued . . .)

that it must grant the defendant’s motion to dismiss because the Court lacks subject-matter jurisdiction.

I. BACKGROUND

A. Statutory Background The Rehabilitation Act provides that “[n]o otherwise qualified individual with a disability in the United States . . . shall, solely by reason of her or his disability . . . be subjected to discrimination” by a federal agency. 29 U.S.C. §§ 794(a)–(b); see Zano v. McDonough, No. 22- 2748 (RBW), 2024 WL 2699976, at *11 (D.D.C. May 24, 2024) (Walton, J.). The Americans with Disabilities Act has been incorporated into the Rehabilitation Act, and also prohibits federal agencies from “discriminat[ing] against a qualified individual on the basis of disability in regard to job application procedures, the hiring, advancement, or discharge of employees, employee compensation, job training, and other terms, conditions, and privileges of employment.” 42 U.S.C. § 12112(a); see also 29 U.S.C. § 791(f); Qashu v. Rubio, 172 F.4th 28, 33 (D.C. Cir. 2026) (same).

If a federal employee believes that his or her rights under the Rehabilitation Act are not being enforced, the employee may sue to enforce them. See Ali v. Regan, 111 F.4th 1264, 1268 (D.C. Cir. 2024). “To prevail, an employee must allege and prove that: (1) [s]he is disabled, (2) h[er] employer had notice of the disability, and (3) the employer denied h[er] request for a

(continued . . .) (Jan. 18, 2024) (“Jan. 2024 Mot. Hr’g Tr.”), ECF No. 14; (4) the Transcript of Motion Hearing Before the Honorable Reggie B. Walton (Sept. 13, 2024) (“Sept. 2024 Mot. Hr’g Tr.”), ECF No. 24; (5) Def.’s Mem., Ex. A (“Pl.’s MSPB Appeal Form”), ECF No. 26-1; (6) Def.’s Mem., Ex. B (“Merit Systems Protection Board (“MSPB”) Initial Decision”), ECF No. 26-2; (7) Def.’s Mem., Ex. C (“Pl.’s Formal Equal Employment Opportunity (“EEO”) Complaint”), ECF No. 26-3; (8) Def.’s Mem., Ex. D (“Equal Employment Opportunity Commission (“EEOC”) Decision on Request for Reconsideration”), ECF No. 26-4; (9) Def.’s Mem., Ex. E (“MSPB Proof of Final Decision”), ECF No. 26-5; (10) Def.’s Mem., Ex. H (“EEO Complaint Confirmation”), ECF No. 26-8; (11) the Plaintiff’s Memorandum of Law in Opposition to the Defendant’s Motion to Dismiss (“Pl.’s Opp’n”), ECF No. 27; and (12) the Reply in Further Support of Defendant’s Motion to Dismiss (“Def.’s Reply”), ECF No. 29.

reasonable accommodation.” Id. at 1268–69. A reasonable accommodation includes “job restructuring, part-time or modified work schedules, reassignment to a vacant position, acquisition or modification of equipment or devices, appropriate adjustment or modifications of examinations, training materials or policies, the provision of qualified readers or interpreters, and other similar accommodations for individuals with disabilities.” 42 U.S.C. § 12111(9). Equal Employment Opportunity Commission regulations further specify that “reasonable accommodations” include “[m]odifications or adjustments to the work environment, or to the manner or circumstances under which the position held or desired is customarily performed, that enable an individual with a disability who is qualified to perform the essential functions of that position,” as well as “[m]odifications or adjustments that enable . . . [an] employee with a disability to enjoy equal benefits and privileges of employment as are enjoyed by [the employer’s] other similarly situated employees without disabilities.” 29 C.F.R. §§ 1630.2(o)(1)(ii)–(iii).

The employee bears the “initial burden of showing that a reasonable accommodation is possible.” Ali, 111 F.4th at 1269. “Once that showing is made, an employer may still avoid liability by showing that the proposed accommodation would impose an ‘undue hardship’ on the employer’s operations.” Id. (citing 42 U.S.C. §§ 12111(10)(A), 12112(b)(5)(A)). An employer fully satisfies its statutory obligation by offering an accommodation that is reasonable, even if it is not the one preferred by the employee. Aka v. Wash. Hosp. Ctr., 156 F.3d 1284, 1305 (D.C. Cir. 1998).

Aggrieved federal employees who believe that their employing agency engaged in conduct prohibited by the Act must “exhaust administrative remedies before they can [sue] to enforce [its] protections.” Doak v. Johnson, 798 F.3d 1096, 1099 (D.C. Cir. 2015) (citing

Barkley v. U.S. Marshals Serv., 766 F.3d 25, 33 (D.C. Cir. 2014)). This requirement necessitates that the individual “submit[] a claim to the employing agency itself[,]” id. at 1099 (citing Kizas v. Webster, 707 F.2d 524, 543–44 (D.C. Cir. 1983)), “within 45 days of the date of the [alleged discriminatory action,]” id. (citing 29 C.F.R. § 1614.105(a)(1)) (internal quotations omitted). The requirement is essential because “[t]he Act limits judicial review to employees aggrieved by the final disposition of their administrative complaint.” Spinelli v. Goss, 446 F.3d 159, 162 (D.C. Cir. 2006) (citing 29 U.S.C. 794a(a)(1)) (internal quotations omitted); Barkley, 766 F.3d at 34 (“[T]he requirement that the aggrieved employee first seek an administrative resolution . . . commands strict adherence.”).

Additionally, federal employees bring a “mixed case” when they “assert[]

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