Catlett Et Al. v. United States

How later courts describe this case

• holding that noncompliance with a notice of claim provision in the District of Columbia Code does not bar federal causes of action
• holding that plaintiff’s noncompliance with D.C.Code § 12-309 cannot bar federal claims
• noting "[t]he EPA’s rule also furthers the purpose of the Congress”
• case for assimilation of § 1983 and Bivens caselaw "is especially strong” in constitutional tort actions against District of Columbia
• D.C.Code § 12-309, establishing a six-month notice requirement for unliquidated damage claims against the District of Columbia, does not apply to constitutional tort claims that are creations of federal law