SIGNIFICANT CASE SUMMARY

Washington DC Case Summary

Geraci v. Hamilton
District of Columbia Court of Appeals
No. 22-CV-0749

Decided: February 5, 2026

Appellate Court dismisses appeal filed following the denial of summary judgment.

Background

Plaintiff sued an individual Defendant – a social worker – and the practice where she worked, alleging professional malpractice and intentional infliction of emotional distress. Defendant is a licensed clinical social worker and a mandatory reporter under D.C. Code § 4- 1321.02(a)(17), as a professional who must make a report to child services or the police department “if they know or have reasonable cause to believe” that a child has been the victim of sexual abuse or is in immediate danger thereof. Defendants moved for summary judgment, arguing that there is statutory immunity for mandatory reporters and that there was no genuine dispute of fact sufficient to rebut the presumption that Defendant’s report was made in good faith. The Court denied the Motion for summary judgment, noting that there was evidence the reporter’s actions leading to her report “were driven by bias, personal malice, or ill will” and that a “jury must decide whether [the] report was made in good faith and whether statutory immunity applies.” Defendants appealed the Trial Court’s denial of its Motion.

To determine if this appeal was appropriate, the Court had to determine if the Order denying summary judgment was a final order that resolved the case on the merits. Generally, a denial of a summary judgment motion is not a final order because it does not definitively end the case. However, under the collateral order doctrine, an interlocutory order is appealable before the close of the case if it conclusively determines a disputed question of law, it resolves an important issue that is separate from the merits of the case, and it is effectively unreviewable on appeal from a final judgment. This case hinged on the third prong regarding reviewability. The Court looked at the plain text of the statute to support its decision and noted that the legislative history does not indicate an intent to prevent discovery and trial.

Holding

The Court of Appeals found that statutory immunity is effectively reviewable because the statute calls for immunity from liability, not immunity from suit. Accordingly, the Court dismissed the appeal and remanded for further proceedings.

Questions about this case can be directed to Scott Edley at 771.210.5150 or sedley@tthlaw.com.