UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
ARRIYANNA PATTON,
Plaintiff,
v. Civil Action No. 25-4223 (JEB)
NATIONAL JOURNAL GROUP, LLC, et
al.,
Defendants.
MEMORANDUM OPINION
Plaintiff Arriyanna Patton brings this pro se action against National Journal Group, LLC
and Gravity Research, LLC for violations of Title VII of the Civil Rights Act. She alleges that
Defendants subjected her to unequal treatment and that her race was a motivating factor in such
treatment and her subsequent termination. Gravity Research now moves to dismiss the
Complaint on several grounds. Because Defendant is non sui juris — i.e., not an entity capable
of being sued — the Court will grant the Motion.
I. Background
The Court draws on the facts as pled in the Complaint, taking them to be true. See
Animal Def. Fund v. Vilsack, 111 F.4th 1219, 1223 (D.C. Cir. 2024). It also considers
additional facts set forth in the undisputed documents attached to the Motion that are integral to
the claim, as well as matters of which it may take judicial notice, which it may do without
converting the Motion into one for summary judgment. See EEOC v. St. Francis Xavier
Parochial Sch., 117 F.3d 621, 624 (D.C. Cir. 1997); Pernice v. Bovim, 2015 WL 5063378, at *3
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(D.D.C. Aug. 26, 2015) (explaining that courts may consider documents attached by defendant to
motion to dismiss “if they are integral to its claim, they are referred to in the complaint, and their
authenticity is undisputed”).
Patton is a Black woman who was employed with National Journal Group as Director of
Partnerships and Strategy at its in-house division called Gravity Research starting in November
2022. See ECF Nos. 1 (Compl.), ¶¶ 39, 44; 23 (Opp.) at 7. She alleges that she was first
subjected to unequal treatment during her hiring process, when despite having comparable
qualifications to a non-Black male employee who previously held the same role, she was
“initially offered a downgraded title and salary.” Compl., ¶¶ 51–53. On multiple occasions
thereafter, Plaintiff raised concerns about unequal treatment, including “an unequal workload,
black employees being historically singled out at the company, and black employees being afraid
to speak out about these issues due to fear of retaliation.” ECF No. 1-1 (EEOC Charge) at 1.
Patton alleges that raising such concerns resulted in “increased scrutiny and hostility from
management,” culminating eventually in her termination. See Compl., ¶¶ 65, 86.
Seven months later, Plaintiff filed a Charge of Discrimination with the EEOC, accusing
National Journal of subjecting her to unequal treatment on several occasions and retaliating when
she raised concerns about the same. See EEOC Charge at 1–2. The EEOC issued a Notice of
Right to Sue on September 7, 2025. Id. at 3–4 (Notice of Right to Sue). Having received that
Notice, Patton filed the current action on December 4, 2025, which asserts four counts under
Title VII: (1) race discrimination; (2) retaliation; (3) hostile work environment; and (4)
constructive discharge. See Compl., ¶¶ 1–38. Gravity Research now moves to dismiss on a
number of grounds.
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II. Legal Standard
Federal Rule of Civil Procedure 12(b)(6) provides for the dismissal of an action where a
complaint fails to “state a claim upon which relief can be granted.” Although “detailed factual
allegations” are not necessary to withstand a Rule 12(b)(6) motion, Bell Atl. Corp. v. Twombly,
550 U.S. 544, 555 (2007), “a complaint must contain sufficient factual matter, accepted as true,
to state a claim to relief that is plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009)
(quotations marks and citation omitted). In weighing a motion to dismiss, a court “may consider
only the facts alleged in the complaint, any documents either attached to or incorporated in the
complaint[,] and matters of which [the court] may take judicial notice.” St. Francis Xavier
Parochial Sch., 117 F.3d at 624. The court must “accept the well-pleaded factual allegations as
true and draw all reasonable inferences from those allegations in the plaintiff’s favor.” Animal
Legal Def. Fund, 111 F.4th at 1223 (citation omitted). It need not accept as true, however, “a
legal conclusion couched as a factual allegation” nor an inference unsupported by the facts set
forth in the complaint. Trudeau v. FTC, 456 F.3d 178, 193 (D.C. Cir. 2006) (quoting Papasan v.
Allain, 478 U.S. 265, 286 (1986)). Pro se litigants are held to a lower standard, as the court must
consider and accept as true the allegations in both their complaint and opposition to a motion to
dismiss. See Brown v. Whole Foods Mkt. Grp., Inc., 789 F.3d. 146, 152 (D.C. Cir. 2015).
III. Analysis
In seeking dismissal of Plaintiff’s Title VII claims, Gravity Research raises several issues
relating to service, administrative exhaustion, its status under Title VII’s definition of
“employer,” and its apparent non-existence as an independent legal entity. See ECF No. 21
(MTD) at 6–10. The Court need only consider Defendant’s position that it is not an entity
capable of being sued.
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Under D.C. law, “unincorporated divisions of a corporation lack legal capacity to be
sued.” Smartdoor Holdings, Inc. v. Edmit Indus., Inc., 78 F. Supp. 3d 275, 277 (D.D.C. 2015)
(quoting EEOC v. St. Francis Xavier Parochial Sch., 77 F. Supp. 2d 71, 75–76 (D.D.C. 1999),
aff’d, 254 F.3d 315 (D.C. Cir. 2000)). This principle is grounded in a pragmatic rationale:
unincorporated divisions do not own any assets apart from those owned by the corporation. Id.
Such divisions are non sui juris — that is, not suable entities. See Blue v. District of Columbia,
850 F. Supp. 2d 16, 22 (D.D.C. 2012).
In support of its position, Defendant refers the Court to D.C.’s corporate-registry
information regarding National Journal, comparing it with the absence of such information for
Gravity Research. See MTD at 4–6; see also ECF Nos. 21-2 (MTD, Exh. A (National Journal
Registry Information)); 21-3 (MTD, Exh. B (Gravity Research Registry Information)). Because
Gravity Research is a mere division of National Journal Group and is not itself incorporated —
as is made pellucid by the records generated from D.C.’s public corporate registry, see National
Journal Registry Information; Gravity Research Registry Information — it lacks capacity to be
sued as a matter of law. See, e.g., Smartdoor, 78 F. Supp. 3d at 277.
Plaintiff responds by speculating that Gravity Research exists as a separate legal entity,
notwithstanding the lack of official public records. See Opp. at 9–13. She points to Defendant’s
public-facing materials — including its website, recruiting materials, LinkedIn profile, email
domain, and email signature block — which she argues indicate “independent institutional
identity.” Id. at 10. The claims and the materials upon which she relies, however, are
insufficient to allege that Gravity Research is anything more than an unincorporated division.
Although the Circuit has recognized that a partnership, through such materials, may “[hold] itself
out to third parties as an entity with an independent institutional identity,” it has simultaneously
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noted that doing so does not “by any means” create corporate status. In re Sealed Case, 877 F.2d
83, 90–91 (D.C. Cir. 1989). Patton herself concedes this point. See Opp. at 10–11
(acknowledging that such “holding out does not, by itself, create corporate status” while still
offering it as “evidence” supporting her position). Plaintiff next contends that while Gravity
Research may not be registered in D.C., a lack of registration “does not prove nonexistence in
every jurisdiction.” Id. at 22. Such allegations, pled without any facts to support the inference
that Gravity Research is in fact registered in a different jurisdiction, are the sort of “[t]hreadbare
recitals of the elements of a cause of action, supported by mere conclusory statements,” that are
insufficient to plausibly indicate that Defendant is incorporated. Iqbal, 556 U.S. at 678.
Because Gravity Research is merely an unincorporated division of National Journal, it
lacks capacity to be sued. As a result, Patton’s suit against it must be dismissed. As National
Journal has already admitted to being Plaintiff’s employer, see ECF No. 4 (Answer), ¶ 44;
Compl., ¶ 44, all claims against that Defendant remain.
IV. Conclusion
For the foregoing reasons, the Court will grant Gravity Research’s Motion to Dismiss. A
separate Order so stating will issue this day.
/s/ James E. Boasberg
JAMES E. BOASBERG
Chief Judge
Date: October 1, 2026
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