Leonard v. District of Columbia

Appellants appeal from a decision of the trial court granting appellees’ motion to dismiss their claims for failure to state a cause of action for injunctive and other relief arising out of their discharge from employment with the District of Columbia government. *fn1 Appellants sued for unlawful termination, alleging that they were career civil service employees who had been terminated from their employment without cause, prior notice or due process and in violation of their rights under the Comprehensive Merit Personnel Act of the District of Columbia (CMPA), D. C. Code � 1-601.1 et seq. They also alleged that the Chief Financial Officer (CFO) of the District made false, malicious, reckless and defamatory public declarations that they were incompetent. *fn2 The trial court concluded that appellants’ civil service status had been converted to an “at-will” employment by section 152 of the Omnibus Consolidated Rescission and Appropriations Act of 1996 (OCRA Act) and that the CFO acted lawfully within his broad grant of authority under that Act. The trial court also rejected appellants’ constitutional challenges to the OCRA Act and dismissed their complaint. Appellants argue for reversal on the grounds that: (1) the complaint alleged a justiciable claim that their firings were motivated by bias, political and other unlawful reasons; (2) section 152 did not convert their career status to “at-will” employment; (3) they were terminated in a manner which impugned their reputations thereby requiring a due process “reputation hearing”; and (4) the statute, as applied, unconstitutionally deprived them of procedural and substantive due process. We hold that the OCRA Act implicitly repealed appellants’ career service status and converted them to “at-will” employees subject to discharge without the benefit of the procedures specified in the CMPA. Concluding that the trial court erred in dismissing appellants’ defamation-based claim, we reverse for further proceedings as to that count. Otherwise, we affirm the trial court’s decision.

I. Factual and Procedural Background