Smith v. Dist. of Columbia
| Decision Date | 30 March 2018 |
| Docket Number | Civil Action No. 15–0161 (ABJ) |
| Citation | 306 F.Supp.3d 223 |
| Parties | Gregory SMITH, Plaintiff, v. DISTRICT OF COLUMBIA, et al., Defendants. |
| Court | U.S. District Court — District of Columbia |
Brendan James Klaproth, Klaproth Law PLLC, Washington, DC, Jesse Colin Klaproth, Klaproth Law PLLC, Philadelphia, PA, David Akulian, Law Office of David H. Akulian, Washington, DC, for Plaintiff.
Akua Damali Coppock, Alicia Marie Cullen, Michael K. Addo, Robert A. DeBerardinis, Jr., Office of the Attorney General for the District of Columbia, Washington, DC, for Defendants.
In 2014, plaintiff Gregory Smith was held at the D.C. jail for twenty-three days after a judge ordered that he be released. The District of Columbia has not suggested that there was any legal justification for this undisputed "overdetention"; what is at stake is whether plaintiff has founded his claims for redress on the appropriate legal theories, and whether he has come forward with sufficient evidence to support them.
Plaintiff sued the District of Columbia and two individuals who worked for the Department of Corrections ("DOC"): Jeanette Myrick and Jack Jones. He brought claims against all three defendants under 42 U.S.C. § 1983 for alleged violations of his Fifth Amendment rights, as well as common law claims alleging false imprisonment and negligence. He also brought a claim alleging negligent supervision and training against the District of Columbia. Defendants moved for summary judgment on all of the counts except the negligence claim, see Defs.' Mot. for Partial Summ. J [Dkt. # 73] ( ), and plaintiff filed a cross-motion for summary judgment on all four counts. See Pl.'s Opp. to Defs.' Mot. & Pl.'s Cross–Mot. for Summ. J. on Liability & Entry of a Permanent Inj. [Dkt. ## 75, 77] ("Pl.'s Cross–Mot.").
Defendants moved for summary judgment on the section 1983 claims in Count I on the grounds that: (1) plaintiff has not established the necessary predicate violation of his constitutional rights; (2) the individual defendants are entitled to qualified immunity; and (3) plaintiff has not satisfied the prerequisites for establishing municipal liability under section 1983, that is, the existence of a policy or practice that caused the constitutional deprivation. The Court concludes that there are genuine disputes of material fact on the questions of whether plaintiff’s constitutional rights were violated, and whether the District had a custom or practice concerning its receipt of paperwork that caused plaintiff’s overdetention, and those disputes preclude the entry of summary judgment for plaintiff or the District on Count I. However, the individual defendants are both entitled to qualified immunity, so summary judgment on Count I will be granted in their favor, and the other theories advanced by plaintiff for section 1983 liability will not move forward.
The Court will grant summary judgment on the false imprisonment claim in Count II in favor of plaintiff because no reasonable juror could find that he was lawfully detained. Since plaintiff did not move for summary judgment on his negligence claim in Count III on proper grounds, the Court will deny his motion on that count without prejudice. Finally, the Court will grant the District's motion for summary judgment on the negligent supervision and training claim in Count IV because plaintiff has not come forward with expert testimony to establish the existence of a national standard of care that was breached in this instance.
The following facts regarding plaintiff’s overdetention are undisputed.1
The process by which prisoners are supposed to be released is also largely undisputed.
After a Superior Court judge authorizes an inmate's release during a court appearance, the courtroom clerk generates a release order and prints two copies, both of which are signed by the judge, the clerk, and the U.S. Marshal in charge of the prisoner. Defs.' SOF ¶¶ 4–5, 7; Pl.'s Resp. SOF ¶¶ 4–5, 7. The clerk maintains the court's copy and is responsible for submitting it to the scanning department at the D.C. Superior Court, where the release order is then scanned into a computerized database called Court View. Defs.' SOF ¶¶ 6, 8; Pl.'s Resp. SOF ¶¶ 6, 8. This information is also reflected in another court system called MyJUSTIS. See Defs.' SOF ¶ 17; Pl.'s Resp. SOF ¶ 17. The Marshal retains the second copy and takes the release order and the prisoner to the main cellblock in the courthouse. Defs.' SOF ¶¶ 6, 9–10; Pl.'s Resp. SOF ¶¶ 6, 9–10.
The Marshal hand delivers the release order to a Legal Instrument Examiner ("LIE") or Lead Legal Instrument Examiner ("LLIE") located at a Department of Corrections satellite office within the courthouse, and the DOC employee then uploads the document into a database called the Transaction Management System ("TMS").See Defs.' SOF ¶ 12; Pl.'s Resp. SOF ¶ 12; Ex. 7 to Defs.' Mot. [Dkt. # 73–9] at 19:1–10;2 Ex. B to Pl.'s Cross–Mot. [Dkt. # 75–25] at 54:1–22.3 Once the release order is uploaded in TMS, a Legal Instrument Examiner located in the Records Office at the D.C. jail itself will access the document in TMS and begin processing the inmate's release by performing the series of actions specified by the system. See Defs.' SOF ¶ 12; Pl.'s Resp. SOF ¶ 12; see also Brown Dec. 2015 Dep. at 19:11–20.
Usually, the first step involved in processing the release order is to time stamp it. Pl.'s SOF ¶ 40; Defs.' Resp. SOF ¶ 40.4 The LIE then pulls the hard copy of the inmate's institutional file to ensure that the release order matches the commitment order, and that the inmate's identifying information matches that of other records in the institutional file. See Defs.' SOF ¶ 13; Pl.'s Resp. SOF ¶ 13; see also Brown Dec. 2015 Dep. at 20:4–12; Ex. 8 to Defs.' Mot. [Dkt. # 73–10] at 16:1–8.5 If all of the information matches, the LIE then goes into an internal database called JACCS and makes sure that all of the documents contained in the inmate's institutional file are also in JACCS, and again, that all of the information is consistent across the commitment and release orders. See Defs.' SOF ¶ 14; Pl.'s Resp. SOF ¶ 14; Ex. I to Pl.'s Cross–Mot. [Dkt. # 75–31] at 20:6–19 (describing how once the LIE pulls the institutional file, the LIE enters the data from the order into JACCS).6 If all of the information is consistent, the LIE closes out the case in JACCS, prints the release order, and scans it into another DOC internal system called Paper Clips. See Defs.' SOF ¶¶ 14–15; Pl.'s Resp. SOF ¶¶ 14–15.7
In order to further verify an inmate's paperwork, the LIE must check MyJUSTIS, a court-based system that reflects information that was entered by the court. See Defs.' SOF ¶¶ 16–17; Pl.'s Resp. SOF ¶¶ 16–17. The LIE checks MyJUSTIS to confirm that a release order has been issued in the relevant case, and that there is no commitment order from another case for that inmate. See Defs.' SOF ¶¶ 16–17; Pl.'s Resp. SOF ¶¶ 16–17; see also Jones Dep. at 17:3–18:10. The LIE must also check the Washington Area Law Enforcement System ("WALES") (also known as eAgent) and National Crime Information Center ("NCIC") to make sure there are no outstanding active warrants for the inmate. Defs.' SOF ¶ 19; Pl.'s Resp. SOF ¶ 19.
Once this process is complete, a supervisory LIE is required to double check all of the LIE's work. Defs.' SOF ¶ 20; Pl.'s Resp. SOF ¶ 20. Then, the supervisor prepares a release authorization form. Defs.' SOF ¶ 21; Pl.'s Resp. SOF ¶ 21. While much of this work takes place at the jail, misdemeanor inmates are supposed to be released directly from D.C. Superior Court. Pl.'s SOF ¶ 50; Defs.' Resp. SOF ¶ 50.
Plaintiff filed this lawsuit in D.C. Superior Court on November 14, 2014, see Compl. [Dkt. # 1–1], and defendants removed it to this Court on February 2, 2015. See Notice of Removal [Dkt. # 1]. Plaintiff amended his complaint on April 21, 2016 after the Court granted defendant William Smith's motion to dismiss under Federal Rule of Civil Procedure 12(b)(6). See Smith v. District of Columbia , 149 F.Supp.3d 128 (D.D.C. 2015) ; see also Am. Compl. [Dkt. # 36].
On December 8, 2016, defendants filed their first motion for summary...
To continue reading
Request your trial
-
Hurd v. Dist. of Columbia
...(quoting City of Canton v. Harris , 489 U.S. 378, 391, 109 S.Ct. 1197, 103 L.Ed.2d 412 (1989) )); see also Smith v. District of Columbia , 306 F. Supp. 3d 223, 255 (D.D.C. 2018) (rejecting a claim that the District was deliberately indifferent to the need for training when the plaintiff's e......
-
Barber v. Dist. of Columbia Gov't, 17-cv-620 (KBJ)
...predicate constitutional violation and (2) that a custom or policy of the municipality caused the violation." Smith v. District of Columbia , 306 F. Supp. 3d 223, 241 (D.D.C. 2018) (internal quotation marks and citation omitted). The "threshold inquiry" in a Section 1983 suit "requires cour......
-
United States v. $215, 587.22 in U.S. Currency
... ... Case No.17cv00853(CRC) United States District Court, District of Columbia. Signed March 30, 2018 306 F.Supp.3d 215 Patricia Marie Sulzbach, Marina Carin Stevenson, ... ...
-
Buie v. Dist. of Columbia
...to impose liability on local governments under § 1983 must prove that action pursuant to official municipal policy caused their injury.'” Id. at 242 (quoting v. Thompson, 563 U.S. 51, 60 (2011)). Put otherwise, municipal liability under § 1983 adheres only where “a custom or policy of the m......