A bare label is not a claim – what HR teams should take from a fresh ADA dismissal
A federal judge in Washington has dismissed a D.C. government employee's disability and pregnancy bias claims, ruling the pleadings fell short.
Constance Freeman sued her employer, the District of Columbia Department of Human Services, under the Americans with Disabilities Act, the D.C. Human Rights Act, and the D.C. Protecting Pregnant Workers Fairness Act. She filed without a lawyer. The Department moved to dismiss the entire complaint, and Freeman did not respond to the motion.
On May 11, 2026, Judge Amit P. Mehta of the U.S. District Court for the District of Columbia granted the dismissal without prejudice. That leaves the door open for Freeman to refile with a stronger complaint.
The judge could have ended the case on procedure alone, since Freeman did not oppose the motion. He went through the merits anyway. On the ADA and D.C. Human Rights Act claims, the court said Freeman alleged she has a "mental disability" – and nothing more. That kind of "bare-boned pleading," the judge wrote, is "not sufficient to plausibly establish" a disability that "substantially limits one or more major life activities." The court treated the same shortfall as fatal to the parallel D.C. claim.
The retaliation claim fared no better. Freeman alleged the agency's ADA coordinator twice did not respond to her request to meet. The court said that does not amount to retaliation on its own. She needed to allege...
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