Samaddar, DDS v. District of Columbia

Summary

The court held that the trial court improperly treated failure to exhaust administrative remedies as a jurisdictional defect, because exhaustion is a judicial-administration requirement rather than a limitation on subject matter jurisdiction. The court nevertheless affirmed dismissal because the complaint did not plausibly allege that the Commission’s conduct in processing the design-review application was intentional, egregious, or conscience-shocking enough to violate substantive due process. The court applied the plausibility standard to both the signature and easement allegations and found them conclusory or consistent at most with negligence.