This case involved a subpoena issued by the D.C. Superior Court to the U.S. Park Police, a federal agency, requiring production of bodycam footage, audio, and reports related to a 2022 motor vehicle accident. The underlying litigation was a personal injury lawsuit in Superior Court between private parties, and the Park Police, not a party to that suit, removed the subpoena to federal district court and moved to quash it. The court granted the motion to quash, holding that sovereign immunity bars enforcement of state-court subpoenas against federal agencies. It reasoned that D.C. Superior Court subpoenas are treated as state-court subpoenas under 28 U.S.C. § 1451, and federal sovereign immunity protects agencies from such subpoenas, unlike those issued in federal court where immunity has been waived. The court distinguished contrary precedent as applying only to federal-court subpoenas.
Elizabeth Brokamp, a psychologist licensed in Virginia, sought to provide teletherapy services to clients in the District of Columbia but could not do so without obtaining a District license as a professional counselor. She sued the District of Columbia, arguing that the licensure requirement for professional counselors violated the First Amendment both as applied to her and facially as overbroad. The U.S. District Court for the District of Columbia found that the requirement violated the First Amendment as applied to Brokamp. The court granted her motion for summary judgment in part, denied the District's cross-motion, entered judgment for Brokamp, and awarded her declaratory and injunctive relief preventing enforcement of the relevant licensing provisions against her.
Kayla Smith sued Camden Development Inc. and Jose Mancilla for sexual harassment under Title VII and D.C. law, plus common-law negligence and battery, alleging that Camden's "Hug Life" hugging policy fostered a hostile work environment that led to her sexual assault by Mancilla at work. After the court dismissed all federal claims against Camden and resolved most other claims, Mancilla moved to dismiss the remaining D.C.-law claims against him for lack of subject-matter jurisdiction. The court denied the motion, holding that it possessed supplemental jurisdiction over the state-law claims and would exercise its discretion to retain them given the case's advanced stage, extensive discovery with overlapping facts, and the plaintiff's choice of forum.
In United States v. Canarte, the defendant pleaded guilty in 2022 to conspiracy to distribute fentanyl, illegal receipt of a firearm while under indictment, and second-degree theft, offenses committed while on supervision for a prior conviction; this resulted in a criminal history score of 10 under then-applicable Sentencing Guidelines that added two points for such conduct, leading to a 53-month sentence via a binding plea agreement. After the Sentencing Commission amended the Guidelines in 2023 to add only one point instead, Canarte moved under 18 U.S.C. § 3582(c)(2) to reduce his sentence to 51 months based on the lowered range. The court first confirmed that the reduction was consistent with applicable policy statements but then denied it after weighing the § 3553(a) factors, emphasizing Canarte's post-sentencing prison infractions involving weapons possession and threats, as well as his recent guilty plea to attempted assault with a dangerous weapon. The court concluded that deterrence and public protection considerations, along with his broader criminal history, did not support any reduction.
Emi Mallon, a pro se plaintiff, sued her former employer, the Secretary of the U.S. Department of Veterans Affairs, alleging sex discrimination and other misconduct in violation of Title VII and the Rehabilitation Act. The district court dismissed the case without prejudice for failure to serve process. Although the court twice extended the deadline under Federal Rule of Civil Procedure 4(m) and specifically instructed Mallon that she needed to serve the civil-process clerk at the U.S. Attorney’s Office for the District of Columbia in addition to the Attorney General and the agency head, her filings never demonstrated compliance with Rule 4(i). The court found no basis to grant further extensions after these warnings, citing the D.C. Circuit’s rule that pro se status does not excuse noncompliance with the Federal Rules.
Touraj Zakeri, an Iranian-born Canadian citizen, applied for a U.S. tourist visa in August 2022, which was refused and placed in administrative processing after interviews. He previously sued government officials to compel adjudication of his application, but that case was dismissed in July 2024 for lack of standing and failure to state a claim. In this second lawsuit filed in September 2025 against the Secretary of State and Consul General, Zakeri brought similar claims under the Mandamus Act and Administrative Procedure Act alleging unreasonable delay. The court dismissed the case, holding that Zakeri lacked standing to sue the Secretary of State and failed to state a claim because the delay was not unreasonable under the TRAC factors, given the government's interests and the lack of bad faith.