Wilson v. DNC Servs. Corp.

315 F. Supp. 3d 392
CourtCourt of Appeals for the D.C. Circuit
DecidedJune 22, 2018
DocketCase No. 1:17–cv–00730 (TNM)
StatusPublished
Cited by10 cases

This text of 315 F. Supp. 3d 392 (Wilson v. DNC Servs. Corp.) is published on Counsel Stack Legal Research, covering Court of Appeals for the D.C. Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wilson v. DNC Servs. Corp., 315 F. Supp. 3d 392 (D.C. Cir. 2018).

Opinion

TREVOR N. MCFADDEN, United States District Judge

Plaintiff Willie Lee Wilson is an African-American citizen who ran in the 2016 *395Democratic presidential primary. Mr. Wilson and his campaign committee allege in their Amended Complaint that the DNC Services Corporation, doing business as the Democratic National Committee, or DNC, discriminated against Mr. Wilson and thwarted his campaign efforts because of his race. They seek $2 million in compensatory damages and $5 million in punitive damages under four theories of recovery: breach of contract, promissory estoppel, race discrimination in violation of the right under 42 U.S.C. § 1981 to make and enforce contracts, and conspiracy to violate civil rights under 42 U.S.C. § 1985. Plaintiffs' breach of contract and promissory estoppel theories fail because the Amended Complaint does not adequately allege the existence of a contract that the DNC breached or of an unkept promise by the DNC on which the Plaintiffs reasonably relied. But it would be premature to dismiss Plaintiffs' Section 1981 and Section 1985 claims at this early stage in the proceedings. Thus, the DNC's Motion to Dismiss will be granted in part and denied in part.

I. BACKGROUND

Mr. Wilson describes himself as the son of a sharecropper, an entrepreneur with a rags-to-riches story, a philanthropist, and a religious motivational speaker. Am. Compl. 1, ¶¶ 5, 8. Mr. Wilson ran in the 2016 Democratic presidential primary, formally registering his campaign committee with the Federal Election Commission in May 2015 and qualifying to be on the ballot in nine or ten states. Id. 2, ¶¶ 7, 10, 52. Mr. Wilson describes his message as one of "governmental accountability, equal justice, business development and social and economic opportunity." Id. ¶ 6. He believes this message appeals to working and middle-class Americans and that his candidacy had the potential to attract "prospective African-American and other voters." Id. ¶¶ 7-8. According to Mr. Wilson, DNC leadership intended to "ensure" that Hillary Clinton won the Party's nomination and "viewed Candidate Wilson's race and the potential racial implications of his candidacy as a threat." Id. ¶¶ 7, 9.

At the end of May 2015, Mr. Wilson advised the DNC through counsel that he intended to seek the Party's nomination. Id. Exs. B, D 3.1 On July 6, 2015, counsel contacted the DNC a second time, asking for confirmation that the DNC "recognized" Mr. Wilson and seeking information about the nomination process, the DNC debate schedule, and any other resources the DNC could offer. Id. Ex. C. In response, the DNC introduced counsel to its Party Affairs Director, who sent counsel several documents about the nomination and delegate selection process. Id. Ex. D 1. It also explained that Mr. Wilson's campaign would need to meet certain threshold requirements to participate in the Democratic primary debates or in a meeting the DNC would hold that August. Id. Ex. D 2. Finally, the DNC offered to answer any further questions and introduced counsel to its National Political Director as a contact who could answer state-specific questions and who could make introductions to state Party leadership if the campaign needed them. Id. According to Mr. Wilson, this correspondence constituted a promise "to provide assistance to Candidate Wilson in the form of introductions to *396State Party officials, logistical resources, and general political assistance." Id. ¶ 37.

Mr. Wilson alleges that, despite this promise, the DNC "acting through its officers, agents, employees, and other independent contractors and representatives ... collaborated, conspired, and agreed amongst themselves to hamper, impede and sabotage [his] campaign." Id. ¶ 92. According to Mr. Wilson, the DNC resisted his campaign efforts by barring him from DNC-sponsored events and encouraging state Party officials to bar him from events that they organized. Id. ¶¶ 41-43. In particular, the DNC denied Mr. Wilson access to its August meeting. Id. ¶¶ 45-48, 56-58. And the DNC acquiesced in a decision by Secret Service agents2 detailed to Mrs. Clinton's security team to keep Mr. Wilson off the stage at multi-candidate campaign event co-sponsored by the DNC and the South Carolina Democratic Committee, even though Mr. Wilson had been invited to appear on stage. ¶¶ 93-104. Mr. Wilson also alleges that the DNC inhibited his campaign by refusing to "sanction" it, which prevented him from gaining ballot access in many of the 19 states where he sought to register.

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Bluebook (online)
315 F. Supp. 3d 392, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wilson-v-dnc-servs-corp-cadc-2018.