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govinfo:USCOURTS-dcd-1_24-cv-03035-0

U.S. District Court for the District of Columbia · 2026-05-27

· GavelSight synced 2026-09-06 03:49:41

UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF COLUMBIA 
 
_________________________________________ 
 ) 
PHIL EHR FOR CONGRESS ) 
CAMPAIGN COMMITTEE, ) 
 ) 
 Plaintiff, ) 
 ) 
 v. ) Case No. 24-cv-3035 (APM) 
 ) 
GRASSROOTS ANALYTICS, INC., ) 
 ) 
 Defendant. ) 
_________________________________________ ) 
_________________________________________ 
 ) 
GRASSROOTS ANALYTICS, INC., ) 
 ) 
 Counterclaim-Plaintiff, ) 
 ) 
 v. ) 
 ) 
PHIL EHR FOR CONGRESS ) 
CAMPAIGN COMMITTEE; ) 
PHIL EHR FOR SENATE CAMPAIGN ) 
COMMITTEE; PHIL EHR, ) 
 ) 
 Counterclaim-Defendants. ) 
_________________________________________ ) 
 
ORDER 
 This is a breach of contract dispute in which Defendant/Counterclaim-Plaintiff Grassroots 
Analytics, Inc. seeks to recover unpaid fees for text-messaging fundraising services that it provided 
to Counterclaim-Defendant Phil Ehr ’s (“Ehr”) campaign for Congress. Plaintiff/Counterclaim -
Defendant Phil Ehr for Congress Campaign Committee (“Campaign”) originally sued Grassroots, 
seeking “recission” of the agreement or, alternatively, damages for breach of contract. Compl., 
ECF No. 1, at 9 –12. Grassroots in tur n counterclaimed against both the Campaign and Ehr 

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individually for breach of contract or, alternatively, unjust enrichment. Grassroot s’ Answer, 
Affirmative Defenses, and Counterclaims, ECF No. 4, at 14–17. 
Grassroots then moved for summary judgment as to both its claims and the Campaign’s. 
Grassroots’ Mot. for Summ J., ECF No. 43 [hereinafter Grassroots’ Mot.]. It sought to hold Ehr 
individually liable as the Campaign’s “alter ego.” Grassroots’ Corrected Mem. in Support of 
Grassroots’ Mot., ECF No. 49 -1, at 10 –18. In response, the Campaign conceded to entry of 
summary judgment against it. See Ehr’s Resp. to Grassroots’ Mot., ECF No. 48 [hereinafter Ehr’s 
Resp.], at 1 ( conceding t he Campaign “ does not oppose summary judgment dismissing its 
complaint and for judgment ”). Ehr, however, opposed, arguing that he could not be held 
individually liable under an alter ego theory. See id. at 2–8. He submitted a declaration in support. 
See Ehr’s Resp., Decl. of Phil Ehr in Opp’n to Mot. for Summ. J., ECF No. 48 -1 [hereinafter Ehr 
Decl.]. 
Given the Campaign’s concession, the court hereby enters summary judgment in favor of 
Grassroots on its breach of contract claim against the Campaign and the Campaign’s recission and 
breach of contract claims. The court , however, denies Grassroots’ motion insofar as it seeks 
judgment on its alternative theory of unjust enrichment. See In re AP A Assessment Fee Litig. , 
766 F.3d 39, 46 (D.C. Cir. 2014) (“Unjust enrichment will not lie when the parties have a contract 
governing an aspect of their relation, be cause a court will not displace the terms of that contract 
and impose some other duties not chosen by the parties.” (cleaned up)). 
As to Ehr, the court denies Grassroots’ motion. There remains a genuine dispute of material 
fact as to whether Ehr can be held liable as the Campaign’s alter ego. See Vuitch v. Furr, 482 A.2d 
811, 816 n.6 (D.C. 1984) (“It is an equitable doctrine, but the issue of whether the corporate veil 
should be pierced is properly submitted to a jury.”); U.S. ex rel. Miller v. Bill Harbert Int'l Constr., 

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No. 95-cv-1231 (RCL), 2007 WL 861094, at *1 (D.D.C. Mar. 20, 2007) (“In light of the fact -
specific nature of the determination, the Court finds that an alter ego analysis is a matter for the 
jury.”). Ehr’s Declaration, for instance, raises questions about the extent of his day-to-day control 
over the Campaign and contests that he intermingled campaign and personal funds. See generally 
Ehr Decl. The court therefore cannot conclude, as matter of law, that Ehr so dominated the 
Campaign “as in reality to neg ate its separate personality.” Founding Church of Scientology of 
Wash., D. C., Inc. v. Webster, 802 F.2d 1448, 1452 (D.C. Cir. 1986) (citation omitted). 
For the foregoing reasons, Grassroots’ Motion for Summary Judgment, ECF No. 43, is 
granted in part and denied in part. The parties shall appear for a remote status conference on June 
8, 2026, at 9:15 AM to discuss a schedule for future proceedings. If Grassroots does not wish to 
proceed to a trial against Ehr, the parties (including the Campaign) shall file a Joint Status Report 
by June 4, 2026, which advises how they intend to resolve this matter. 
 
 
 
Dated: May 27, 2026 Amit P. Mehta 
 United States District Judge 
 
 

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