PAUL L. FRIEDMAN, UNITED STATES DISTRICT JUDGE
This matter came before the Court on the defendants’ motion for judgment on the pleadings pursuant to Rule 12(c) of the Federal Rules of Civil Procedure. By Order of September 30, 2013, the Court granted the defendants’ motion as to the plaintiff’s sole federal law claim and dismissed the plaintiff’s remaining claims without prejudice. This Opinion explains the reasoning underlying that Order.
For the purposes of this motion, the Court accepts as true all facts as alleged in the complaint. On or about May 21, 1989, Dr. Angela Yancey accepted a position with the District of Columbia Department of Mental Health (“DMH”) to work as a psychologist in the Forensic Inpatient Division of St. Elizabeths Hospital (“St. Elizabeths”). Compl. ¶ 8. St. Elizabeths is a federally-funded psychiatric hospital located in, and operated by, the District of Columbia. Id. ¶ 2.
Upon her hiring by DMH, Dr. Yancey was led to believe that she would be eligible for benefits under the Civil Service Retirement System–Law Enforcement (“CSRS-LE”), a federal retirement benefits program. Compl. ¶ 9. Dr. Yancey’s employment at St. Elizabeths continued for over twenty years, until she retired on July 31, 2009. Id. ¶¶ 11-12. During the course of Dr. Yancey’s employment, DMH deducted $88, 985 from her salary for retirement benefits, while continuing to represent that she was covered under the CSRS-LE retirement plan. Id. ¶ 12. Dr. Yancey retired based on representations made by DMH and St. Elizabeths “that she was eligible for retirement under the CSRS-LE and that she would receive a retirement incentive award payment in the amount of $25, 000.00.” Id. ¶ 14.
On September 18, 2009, Dr. Yancey was notified that “the government of the District of Columbia had erroneously coded her retirement benefits” and that she would not receive the $25, 000 retirement incentive award that she expected. Compl. ¶ 16. Nor would she receive her retirement benefits through the CSRS-LE. Id. Dr. Yancey does not allege that she is deprived of retirement benefits entirely (i.e., that alternative benefits are unavailable), but rather that she is deprived of those specific benefits – the incentive award and the CSRS monthly annuity – that she was promised. See id. ¶¶ 14, 16-17; Defs.’ Mot. 3; Pl. Opp. 13. Dr. Yancey claims that she “has suffered significant financial and emotional injuries because of her reliance on the unfulfilled promises and representations from the defendants.” Compl. ¶ 21.
On November 12, 2010, Dr. Yancey filed suit in this Court against the District of Columbia, DMH, and St. Elizabeths, bringing five claims against the defendants. Dr. Yancey’s first three claims – (1) detrimental reliance/promissory estoppel; (2) breach of contract; and (3) fraudulent misrepresentation – are brought under District of Columbia common law. See Compl. ¶¶ 18-34. Dr. Yancey’s fourth claim is presented as a request for declaratory relief, in which she asks the Court to declare that she is eligible for benefits under the CSRS-LE program and any other relief the Court deems appropriate. Id. ¶¶ 35-37 (Count IV).
Dr. Yancey’s fifth and final claim is a federal constitutional claim based on the denial of property rights under color of law. Compl. ¶¶ 38-39 (Count V). Dr. Yancey alleges that the District denied her property rights without due process of law and without just compensation. Id. ¶ 39. Dr. Yancey does not clearly indicate whether she is bringing a procedural due process claim or a takings claim. Id.; see also Pl.’s Opp’n 13-14.
On March 29, 2013, defendant St. Elizabeths Hospital was dismissed from this case because Dr. Yancey had failed to submit proof of service within the 120-day period required by Rule 4(m) of the Federal Rules of Civil Procedure, and had failed to respond to a court order to show cause as to why St. Elizabeths should not be dismissed. See Dismissal Order. After limited discovery concluded, the District of Columbia moved for judgment on the pleadings. The District argues that Count V fails to state a claim, and that, without this federal law claim, the Court lacks original jurisdiction over any claim in this case. See Defs.’ Mot 1; 7-12. The District contends that the remaining claims in this case therefore should be dismissed. Id. at 1, 12-13. Alternatively, the District asserts that those claims should be dismissed for failure to state a claim and lack of exhaustion of administrative remedies. Id. at 1, 13-24.
II. LEGAL STANDARD
Rule 12(c) of the Federal Rules of Civil Procedure states that “[a]fter the pleadings are closed – but early enough not to delay trial – a party may move for judgment on the pleadings.” Fed.R.Civ.P. 12(c). The standard of review for a motion for judgment on the pleadings on the ground that the plaintiff has failed to state a claim “is functionally equivalent to a Rule 12(b)(6) motion” for failure to state a claim. Rollins v. Wackenhut Servs., Inc., 703 F.3d 122, 130 (D.C. Cir. 2012); see Lockhart v. Coastal Int’l Sec., Inc., 905 F.Supp.2d 105, 114 (D.D.C. 2012) (on Rule 12(c) motion, “courts employ the same standard that governs a Rule 12(b)(6) motion to dismiss”). The Supreme Court’s recent decisions in Ashcroft v. Iqbal, 556 U.S. 662 (2009), and Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007), therefore apply to Rule 12(c) motions. Rollins v. Wackenhut Servs., Inc., 703 F.3d at 129-30; Lockhart v. Coastal Int’l Sec., Inc., 905 F.Supp.2d at 114. On either a Rule 12(b)(6) or Rule 12(c) motion, a court may rely only on “facts alleged in the complaint, documents attached to the complaint as exhibits or incorporated by reference, and matters about which the court may take judicial notice.” Cole v. Boeing Co., 845 F.Supp.2d 277, 283 (D.D.C. 2012) (citing Abhe & Svoboda, Inc. v. Chao, 508 F.3d 1052, 1059 (D.C. Cir. 2007)). A court may grant the motion only if the facts alleged in the complaint do not “state a claim to relief that is plausible on its face.” Bell Atlantic Corp. v. Twombly, 550 U.S. at 570.
III. COUNT V – DENIAL OF PROPERTY RIGHTS UNDER COLOR OF LAW
Dr. Yancey appears to bring Count V – a claim of denial of property rights under color of law – under 42 U.S.C. § 1983. Compl. ¶ 5; Pl.’s Opp. 13-14. “To state a claim under § 1983, the plaintiff must allege the deprivation of ‘rights, privileges, or immunities secured by the Constitution and laws’ by a person acting under color of state, territorial or District of Columbia law.” Smith v. Fenty, 684 F.Supp.2d 64, 66-67 (D.D.C. 2010) (quoting 42 U.S.C. § 1983). To establish municipal liability under Section 1983, a plaintiff must show that the municipality implemented or executed a policy, custom or practice that caused the deprivation of an individual’s constitutional rights. Monell v. Dep’t of Social Servs., 436 U.S. 658, 690-91 (1978).
In Baker v. Dist. of Columbia, 326 F.3d 1302, 1306 (D.C. Cir. 2003), the D.C. Circuit noted that when evaluating a claim for municipal liability, the district court must conduct a two-step inquiry. First, the court must determine “whether the complaint states a claim for a predicate constitutional violation.” Id. If it does, then the court must determine “whether the complaint states a claim that a custom or policy of the municipality caused the violation.” Id. “Each inquiry is separate and serves different purposes.” Id. The order in which a court undertakes each analytical step is not important. See Olaniyi v. Dist. of Columbia, 876 F.Supp.2d 39, 47-53 (D.D.C. 2012) (finding no municipal liability based on the plaintiff’s failure to establish policy or practice, without deciding ...