COTTEN v. DISTRICT OF COLUMBIA GOVERNMENT

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
JOANNE TAYLOR COTTEN,
Plaintiff,
v.
DISTRICT OF COLUMBIA
GOVERNMENT,
Defendant.
Civil Action No. 25-01718 (AHA)
Memorandum Opinion
Joanne Taylor Cotten sues the D.C. government and appears to assert a claim for breach of
a collective bargaining agreement between the Washington Teachers’ Union and D.C. Public
Schools. ECF No. 1 at 4–5; see ECF No. 1-3. Cotten alleges the District did not follow an order
from its Office of Employee Appeals “to reinstate [her] as a whole” after she lost her job following
a reduction in force. ECF No. 1 at 4–5; ECF No. 10 at 2, 4. She also alleges that she was terminated
following her reinstatement “due to budget constraints” and not “due to poor performance.” ECF
No. 1 at 4–5; ECF No. 10 at 2, 5. In addition, Cotten appears to take issue with a D.C. Court of
Appeals judgment affirming the dismissal of an earlier suit she filed concerning a claim for breach
of the collective bargaining agreement. ECF No. 1 at 4–5; see ECF No. 1-10 at 1, 3–4. The District
moves to dismiss for lack of subject matter jurisdiction and failure to state a claim. ECF No. 7. For
the reasons below, the court grants the District’s motion to dismiss.1
1 	As required at the pleading stage, the court accepts the complaint’s well-pled factual
allegations and draws all reasonable inferences in Cotten’s favor. Banneker Ventures, LLC v.
Graham, 798 F.3d 1119, 1129 (D.C. Cir. 2015).
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To proceed in federal court, a plaintiff’s complaint must plausibly establish federal subject
matter jurisdiction. See Shuler v. United States, 531 F.3d 930, 932 (D.C. Cir. 2008). In considering
whether the complaint does so, the court must “assume the truth of all material factual allegations
in the complaint and ‘construe the complaint liberally, granting plaintiff the benefit of all
inferences that can be derived from the facts alleged,’ and upon such facts determine jurisdictional
questions.” Am. Nat’l Ins. Co. v. FDIC, 642 F.3d 1137, 1139 (D.C. Cir. 2011) (citations omitted).
Because Cotten is proceeding pro se, the court is careful to give extra leeway, evaluating the
complaint “in light of all filings.” Ho v. Garland, 106 F.4th 47, 50 (D.C. Cir. 2024) (quotation
marks omitted) (quoting Brown v. Whole Foods Mkt. Grp., Inc., 789 F.3d 146, 152 (D.C. Cir.
2015)).
Cotten’s complaint does not allege a basis for subject matter jurisdiction. The jurisdiction
of the federal district courts is generally limited to when a “federal question” is presented or the
parties are citizens of different states and more than $75,000 is in controversy. See 28 U.S.C. §§
1331, 1332. Cotten’s complaint does not present a federal question. Cotten appears to assert a
breach of contract claim, and possibly an intentional infliction of emotional distress claim, against
the District under D.C. law. See ECF No. 1 at 4–5. None of the statutes Cotten invokes provide an
applicable federal cause of action, and the court cannot independently discern any basis for federal
question jurisdiction from the facts alleged in the complaint. See ECF No. 1 at 3; ECF No. 10 at
1; Johnson v. Robinson, 576 F.3d 522, 522 (D.C. Cir. 2009) (per curiam) (“Federal court
jurisdiction must affirmatively appear clearly and distinctly.” (cleaned up)). The complaint also
does not allege diversity jurisdiction. Cotten brings her complaint against the D.C. government,
but it is well-established that “the District is not subject to the diversity jurisdiction of the federal
courts” because it is not considered a “citizen” of a state. Long v. District of Columbia, 820 F.2d
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409, 414 (D.C. Cir. 1987). Accordingly, the court lacks subject matter jurisdiction over Cotten’s
complaint.
Additionally, to the extent Cotten’s complaint seeks relief from a decision of the D.C. Court
of Appeals, this court does not have subject matter jurisdiction to consider it. Under the Rooker-
Feldman doctrine, federal district courts may not hear “cases that amount to the functional
equivalent of an appeal from a state court.” Gray v. Poole, 275 F.3d 1113, 1119 (D.C. Cir. 2002);
see also Rooker v. Fid. Trust Co., 263 U.S. 413 (1923); D.C. Ct. of Appeals v. Feldman, 460 U.S.
462 (1983). This prevents federal courts from considering issues that are “so inextricably
intertwined with a state court decision that the district court is in essence being called upon to
review the state-court decision.” Stanton v. D.C. Ct. of Appeals, 127 F.3d 72, 75 (D.C. Cir. 1997)
(quotation marks and citation omitted). Cotten’s complaint refers to a D.C. Court of Appeals
judgment affirming the dismissal of an action she brought asserting that the District breached the
collective bargaining agreement between the Washington Teachers’ Union and D.C. Public
Schools by failing to transfer her to a specific high school to fill an open counselor position. ECF
No. 1 at 4; see ECF No. 1-10. Cotten appears to request relief from that judgment and challenges
the D.C. Court of Appeals’ statute of limitations analysis. See ECF No. 1 at 4 (asserting that the
“Courts affirmed only on the Statute of limitations” but the “statute of limitations was tolled”);
ECF No. 10 at 2 (requesting that the court “reopen her case”); ECF No. 10 at 3 (asserting that the
“District of Columbia Court of Appeals affirmed” due “to statute of Limitations only,” which
Cotten appears to argue is the “wrong Doctrine”). To the extent Cotten’s action asks this court to
review the propriety of the D.C. Court of Appeals’ decision, it is barred by Rooker-Feldman.2
2 	Cotten’s suit also appears to be barred by the doctrine of res judicata. “Under the doctrine of
res judicata, or claim preclusion, a subsequent lawsuit will be barred if there has been prior
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For these reasons, the District’s motion to dismiss is granted and this action is dismissed
without prejudice. A separate order accompanies this memorandum opinion.
AMIR H. ALI
United States District Judge
Date: 	May 5, 2026
litigation (1) involving the same claims or cause of action, (2) between the same parties or their
privies, and (3) there has been a final, valid judgment on the merits, (4) by a court of competent
jurisdiction.” Smalls v. United States, 471 F.3d 186, 192 (D.C. Cir. 2006). Cotten’s previous suit
against the District for breach of the collective bargaining agreement involved the same parties
and appears to involve the same claims or cause of action. See ECF No. 1-10 at 3–4. That suit
resulted in a final judgment on the merits by the D.C. Court of Appeals. See id.
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