District of Columbia v. Trump, No. 18-2488 (4th Cir. 2020)Annotate this Case
The District of Columbia and the State of Maryland sued the President in his official capacity, alleging violations of the Constitution’s Foreign and Domestic Emoluments Clauses. The district court granted a motion to amend the complaint to add the President as a defendant in his individual capacity. The President, in that capacity, moved to dismiss the action, asserting absolute immunity. Approximately seven months passed without a ruling on that motion. The President in his individual capacity filed an interlocutory appeal. A Fourth Circuit panel concluded that the district court had effectively denied immunity to the President in his individual capacity so that the panel had jurisdiction to consider the interlocutory appeal. “[E]xercising that jurisdiction,” the panel held that Plaintiffs lacked Article III standing and remanded the case with instructions to dismiss.
Acting en banc, the Fourth Circuit vacated the panel opinion and dismissed the interlocutory appeal. The district court neither expressly nor implicitly refused to rule on immunity but stated in writing that it intended to rule on the President’s individual capacity motion. A district court has wide discretion to prioritize its docket and the deferral did not result in a delay “beyond reasonable limits.” During the seven months, the district court managed the many other aspects of this litigation and issued opinions on the President’s motion to dismiss in his official capacity and a motion to certify an interlocutory appeal of the court’s rulings.
This opinion or order relates to an opinion or order originally issued on July 10, 2019.