Case 1:18-cv-01011-RMC Document 42 Filed 08/09/19 Page 8 of 19
emotional distress. See id. ¶¶ 178-89, 228-36 (Counts IV and VIII). 6 The Court will review the
allegations for each count in turn to ensure they are well-plead and justify default judgment.
1. Interference with Places of Public Accommodation (Counts I and V) 7
In the District of Columbia, every individual has the right to “an equal
opportunity to participate in all aspects of life, including, but not limited to . . . in places of
public accommodation.” D.C. Code § 2-1402.01. It is unlawful to directly or indirectly deny
any person the full and equal enjoyment of the goods, services, facilities, privileges, advantages,
and accommodations of any place of public accommodations on the basis of a variety of factors
including race and gender. See id. § 2-1402.31. It is unlawful for any individual “to coerce,
threaten, retaliate against, or interfere with any person in the exercise or enjoyment of . . . any
right granted or protected” under the DCHRA. Id. § 2-1402.61. An individual may not “aid,
abet, invite, compel, or coerce the doing of any of the acts forbidden under the [DCHRA] or . . .
attempt to do so.” Id. § 2-1402.62. “To establish a prima facie case of . . . interference, a
plaintiff must allege that: (1) [s]he engaged in activity protected under the DCHRA . . . ; (2)
[s]he was subjected to adverse action; and (3) there is a causal nexus between the two.”
Mazloum v. District of Columbia, 442 F. Supp. 2d 1, 12 (D.D.C. 2006) (citing CarterObayuwana v. Howard Univ., 764 A.2d 779, 790 (D.C. 2001)).
6
Ms. Dumpson does not move for default judgment on Counts III and VII, alleging bias-related
incitement of and/or conspiracy to commit stalking. See Am. Compl. ¶¶ 159-77, 210-27; Mem.
at 10 n.3.
7
The same prima facia test applies to interference with public accommodation and interference
with educational institution claims. American University is both a place of public
accommodation and an educational institution. Therefore, for the same reasons the Court finds
Counts I and V well-plead, Counts II and VI are also sufficient to justify default judgment.
8