A U.S. District Court has ruled to set aside a default judgment against Kaywin Feldman, the Director of the National Gallery of Art, in a case filed by former employee Olinda Harris. The court's decision allows the case to proceed after Harris challenged her termination, which she claims was due to discrimination related to her medical condition. This ruling is significant as it highlights the complexities of employment law for federal employees.
The case, Harris v. Feldman, was filed on October 20, 2024, under Civil Action No. 2024-1209. It arose after Harris, who began working at the National Gallery of Art in 2013, was terminated in 2022 for absenteeism following a serious car accident that left her in a coma. The court's decision to set aside the default judgment means that the dispute will now be resolved on its merits rather than through a default ruling.
Background
Olinda Harris filed her lawsuit pro se, meaning she represented herself without an attorney. After her termination from the National Gallery of Art, she pursued various legal avenues, including appeals to the Merit Systems Protection Board (MSPB) and the Equal Employment Opportunity Commission (EEOC). However, the details of her claims and the outcomes of those appeals were not clearly outlined in her complaint.
In 2025, the court ordered Harris to show cause as to why her case should not be dismissed due to a lack of prosecution, indicating that she had not actively pursued her claims. After Harris filed an affidavit for default in November 2025, the Clerk of Court entered a default judgment in June 2026 due to Feldman's failure to respond. Feldman later moved to set aside this default, leading to the court's recent ruling.
The Ruling
Judge Royce C. Lamberth presided over the case and ultimately granted Feldman's motion to set aside the default. The court ruled that the default was not willful, as it resulted from a clerical error rather than a deliberate choice to ignore the lawsuit. The judge noted, "Absent clear evidence to the contrary, the Court cannot conclude that Defendant’s failure to respond rises to the level of willfulness. This factor therefore favors Defendant."
The court also considered whether setting aside the default would prejudice Harris. While Harris argued that the delay in responding was unreasonable, the court found that mere delay does not constitute prejudice. Judge Lamberth stated, "Delay in and of itself does not constitute prejudice," emphasizing that the potential for loss of evidence or increased difficulties in discovery would need to be demonstrated.
Impact
This ruling has significant implications for both Harris and the National Gallery of Art. By allowing the case to proceed, the court opens the door for Harris to present her claims regarding her termination and the circumstances surrounding it. The decision also underscores the importance of procedural compliance in employment law cases, particularly for federal employees who may face unique challenges when navigating the legal system.
Furthermore, the court's ruling may set a precedent for similar cases where defendants seek to set aside default judgments. It highlights the courts' preference for resolving disputes on their merits rather than through default judgments, which can often lead to unjust outcomes for parties who may have legitimate defenses.
What's Next
Following the court's decision, Harris has the opportunity to file a Second Amended Complaint within 30 days. If she fails to do so or if her new complaint does not adequately address the deficiencies noted by the court, the case may be dismissed. Meanwhile, Feldman may file a response or other motion within 30 days of any amended complaint. The outcome of this case remains uncertain as it now moves forward in the legal process.