Williams v. District of Columbia

CourtDistrict Court, District of Columbia
DecidedMarch 24, 2023
DocketCivil Action No. 2022-0114
StatusPublished

This text of Williams v. District of Columbia (Williams 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.

Bluebook
Williams v. District of Columbia, (D.D.C. 2023).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA _________________________________________ ) CHRISTOPHER M. WILLIAMS, ) ) Plaintiff, ) ) v. ) Civil Action No. 22-0114 (EGS) ) DISTRICT OF COLUMBIA, et al., ) ) Defendants. ) _________________________________________ )

MEMORANDUM OPINION This matter is before the Court on two motions to dismiss: Defendants Councilmembers

of the Council of the District of Columbia’s Motion to Dismiss Plaintiff’s Complaint (ECF No.

10) and Defendant District of Columbia’s Motion to Dismiss Plaintiff’s Complaint (ECF No. 9).

Because plaintiff has withdrawn his claims against the Councilmember Defendants (ECF No.

14), the Court will deny their motion as moot and dismiss Nyasha Smith, Phil Mendelson, Anita

Bonds, Robert White, Elissa Silverman, Christina Henderson, Brianne Nadeau, Brooke Pinto,

Mary Cheh, Janeese Lewis-George, Kenyan McDuffie, Charles Allen, Vincent Gray and Trayon

White as party defendants.

The District of Columbia adopts the Councilmembers’ argument that dismissal under

Federal Rule of Civil Procedure 12(b)(1) is warranted because plaintiff lacks standing. See Def.

District of Columbia’s Mem. of P. & A. in Support of Mot. to Dismiss. Pl.’s Compl. (ECF No. 9-

1, “DC Mem.”) at 5 n.1; Reply in Further Support of Def. District of Columbia’s Mot. to Dismiss

Pl.’s Compl. (ECF No. 16, “Reply”) at 4-5; Defs. Councilmembers of the Council of the District

of Columbia’s Mem. in Support of Mot. to Dismiss Pl.’s Compl. (ECF No. 10-1,

1 “Councilmembers’ Mem.”) at 3-5.1 In addition, the District moves to dismiss under Federal

Rule of Civil Procedure 12(b)(6) on the ground that the complaint fails to state a claim upon

which relief can be granted. See generally DC Mem. at 10-13. For the reasons discussed below,

the Court GRANTS the District of Columbia’s motion to dismiss.

I. BACKGROUND

The Council of the District of Columbia is responsible for “divid[ing] the District into 8

compact and contiguous election wards, each of which shall be approximately equal in

population size,” D.C. Code § 1-1011.01(c), based on the official report of the federal decennial

census for the District of Columbia, see id. § 1-1011.01(a). “The Council shall, by act after

public hearing, make any adjustment in the boundaries of election wards that is necessary as a

result of population shifts and changes.” Id. § 1-1011.01(b).

The Chair of the Council established a Subcommittee on Redistricting within the

Committee of the Whole (“Subcommittee”) to lead the effort to redraw ward boundaries, see

Compl. ¶ 14; DC Mem. at 6-8, in light of 2020 census data the United States Census Bureau

released in September 2021, see Compl. ¶¶ 14-15. To this end, the Subcommittee “launched a

website on September 17, 2021 to enable the public to create [its] own recommendations on

redrawing ward . . . boundaries,” Compl. ¶ 16, and held public hearings, see id. ¶¶ 18-19.

Plaintiff Christopher Williams, a resident of Southwest, Washington, DC in Ward 6, see

id. ¶ 5, submitted two proposed ward boundary maps, see id. ¶¶ 17, 20, and testified before the

Subcommittee twice, see id. ¶¶ 18-19, recommending that his “Southwest-Waterfront

neighborhood be put into Ward 8 rather than [remain] in its current ward of Ward 6,” id. ¶ 17.

1 In this Memorandum Opinion, all page numbers are those designated by CM/ECF. 2 The complaint quoted at length from testimony plaintiff presented to the Subcommittee at

its September 29, 2021, hearing. See generally id. ¶ 18. Plaintiff stated that “Ward 6 is the

nation’s epicenter of gentrification and Black displacement,” that “[r]acial injustices in housing,

income and health in Southwest are rampant,” and that “conditions in Southwest do not live up

to the U.S. Constitution of Equal Protection under the law.” Id. (emphasis removed). He urged

the Subcommittee “to give serious thought to the harm that this acute gentrification and

redevelopment is causing throughout our black communities west of the Anacostia River[.]” Id.

Further, plaintiff admonished the Council “to take the Constitution seriously around equal

protection of the law.” Id. (emphasis removed). Plaintiff testified at a Subcommittee hearing in

Ward 6 on November 3, 2021, “voic[ing] his support for Southwest moving out of Ward 6 due to

1) poor political representation by a succession of ward representatives, 2) the negative effects of

neighborhood change on Black populations, including displacement, and 3) constitutional

violations.” Id. ¶ 19.

On November 19, 2021, the Subcommittee issued its Report on B24-371, Ward

Redistricting Amendment Act of 2021, recommending, among other matters, that the boundaries

of Wards 6 and 8 be redrawn.2 The boundaries ultimately approved by the full Council and the

Mayor of the District of Columbia left plaintiff’s Southwest Waterfront neighborhood in Ward 6.

See D.C. Code § 1-1041.03 (codifying new ward boundaries pursuant to the Ward Redistricting

Amendment Act of 2021 (D.C. Law 24-74; 69 D.C. Reg. 10) (Jan. 7, 2022)) (“Redistricting

Act”).

Plaintiff brings this “action for declaratory and injunctive relief pursuant to [the] Equal

Protection Clause of the Fourteenth Amendment and the District of Columbia Home Rule Act[.]”

2 The Subcommittee on Redistricting’s report is available at https://bit.ly/3Q6tdaT. 3 Compl. ¶ 1. He claims that the Redistricting Act was “based on [defendants’] errant

interpretation of the Equal Protection Clause of the Fourteenth Amendment” because “[t]his

Clause applies to states, which the District of Columbia is not.” Id. ¶ 2. And, according to

plaintiff, the “redistricting map violates his equal protection rights since the Defendants are

seeking to protect a right that they are not constitutionally or statutorily permitted to uphold.” Id.

¶ 4. In Count One, he asserts:

28. Plaintiff is being irreparably harmed by reason of Defendants’ violations of the Equal Protection Clause of the Fourteenth Amendment. The Defendants erroneously and illegitimately misappropriated the Equal Protection Clause within its congressional authority. 29. By alleging this protection, the Plaintiff’s constitutional rights were abridged because he specifically claimed the equal protection violations as a resident within a highly gentrifying neighborhood characterized by harming Black residents and intense social whitening. Id. ¶¶ 28-29. In Count Two, plaintiff asserts:

32. Plaintiff is being irreparably harmed by reason of Defendants’ violations of the District of Columbia Home Rule Act in that the Defendant[s] failed comply with Congress’ plain and clear self-governance dependent on laws remaining consistent with the Constitution of the United States. 33. The Home Rule Act had neither the intent nor effect of making the District of Columbia a State. Id. ¶¶ 32-33. Plaintiff demands “a declaratory judgment that the Defendants exceeded

constitutional and congressional authority and therefore violated [his] Equal Protection rights,”

an order enjoining implementation of the Redistricting Act, unspecified compensatory damages,

and an award of fees and costs. Id. at 12.

4 II. LEGAL STANDARDS

A. Rule 12(b)(1)

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