Smith v. Dist. of Columbia, Civil Action No. 15–0161 (ABJ)

CourtUnited States District Courts. United States District Court (Columbia)
Writing for the CourtAMY BERMAN JACKSON, United States District Judge
Citation306 F.Supp.3d 223
Parties Gregory SMITH, Plaintiff, v. DISTRICT OF COLUMBIA, et al., Defendants.
Docket NumberCivil Action No. 15–0161 (ABJ)
Decision Date30 March 2018

306 F.Supp.3d 223

Gregory SMITH, Plaintiff,
v.
DISTRICT OF COLUMBIA, et al., Defendants.

Civil Action No. 15–0161 (ABJ)

United States District Court, District of Columbia.

Signed March 30, 2018


306 F.Supp.3d 232

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.

MEMORANDUM OPINION

AMY BERMAN JACKSON, United States District Judge

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

306 F.Supp.3d 233

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] ("Defs.' Mot."), 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.

BACKGROUND

The following facts regarding plaintiff’s overdetention are undisputed.1

• On March 15, 2014, the Department of Corrections ("DOC") received commitment orders in two different D.C. Superior Court misdemeanor cases, 2012 CMD 007806 and 2014 CMD 00445, ordering that plaintiff be committed to the custody of the DOC until further order of the Court. See Defs.' SOF ¶¶ 1–2; Pl.'s Resp. SOF ¶¶ 1–2; Pl.'s SOF ¶ 2;
306 F.Supp.3d 234
Defs.' Resp. SOF ¶ 2; see also Ex. 13 to Pl.'s Cross–Mot. [Dkt. # 75–19] ("Court View Case No. 2014 CMD 004452"); Ex. 14 to Pl.'s Cross–Mot. [Dkt. # 75–20] ("Court View Case No. 2012 CMD 007806").

• On March 18, 2014, plaintiff was transported from D.C. jail to Superior Court, and a judge ordered him to be released in both cases. Defs.' SOF ¶ 3; Pl.'s Resp. SOF ¶ 3; Pl.'s SOF ¶ 4; Defs.' Resp. SOF ¶ 4; see Ex. 1 to Pl.'s Cross–Mot. [Dkt. # 75–7], Ex. 5 to Pl.'s Cross–Mot. [Dkt. ## 75–11, 79] at 30–31 (together, "Release Order Case No. 2012 CMD 007806"); Ex. 2 to Pl.'s Cross–Mot. [Dkt. # 75–8], Ex. 5 to Pl.'s Cross–Mot. [Dkt. ## 75–11, 79] at 35 (together, "Release Order Case No. 2014 CMD 004452"); see also Court View Case No. 2014 CMD 00452; Court View Case No. 2012 CMD 007806.

• DOC received and processed the release order for case number 2014 CMD 004452 on the same day. Defs.' SOF ¶ 22; Pl.'s Resp. SOF ¶ 22.

• Although the DOC received the release order in case number 2012 CMD 007806 on March 18, 2014, the order was not processed. Defs.' SOF ¶ 23; Pl.'s Resp. SOF ¶ 23; Pl.'s SOF ¶ 19; Defs.' Resp. SOF ¶ 19; see also Release Order Case No. 2012 CMD 007806.

• DOC did not release plaintiff from custody on March 18. Pl.'s SOF ¶ 5; Defs.' Resp. SOF ¶ 5.

• Plaintiff was held at the D.C. jail until April 10, 2014. Defs.' SOF ¶ 24; Pl.'s Resp. SOF ¶ 24.

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

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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

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Center ("NCIC") to make sure there are no outstanding active warrants for the inmate. Defs.' SOF ¶ 19; Pl.'s Resp. SOF ¶ 19.

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12 practice notes
  • Hurd v. Dist. of Columbia, Civil Action No. 15-0666 (ESH)
    • United States
    • United States District Courts. United States District Court (Columbia)
    • December 11, 2019
    ...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 expert "di......
  • Brown v. Dist. of Columbia, Civil Action 14-750 (RC)
    • United States
    • United States District Courts. United States District Court (Columbia)
    • January 11, 2022
    ...to a general hospital that participates in the Medicare program.” Pl.'s Higher-Level Opp'n at 6. The Smith v. District of Columbia, 306 F.Supp.3d 223 (D.D.C. 2018), opinion, cited in Defendants' brief for the proposition that “[e]xpert testimony is required to explain the ‘intricacies' of o......
  • Barber v. Dist. of Columbia Gov't, No. 17-cv-620 (KBJ)
    • United States
    • United States District Courts. United States District Court (Columbia)
    • August 13, 2019
    ...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 courts to iden......
  • United States v. $215, 587.22 in U.S. Currency, Case No.17–cv–00853(CRC)
    • United States
    • U.S. District Court — District of Columbia
    • March 30, 2018
    ...Here the complaint is not conclusively time barred—it gives no indication of when the government learned of Szlavik's alleged money 306 F.Supp.3d 223transfers. In any case, the report cited by the Szlaviks concerns President Bongo's use of U.S. accounts to launder money. See Mot. Dismiss Ex......
  • Request a trial to view additional results
12 cases
  • Hurd v. Dist. of Columbia, Civil Action No. 15-0666 (ESH)
    • United States
    • United States District Courts. United States District Court (Columbia)
    • December 11, 2019
    ...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 expert "di......
  • Brown v. Dist. of Columbia, Civil Action 14-750 (RC)
    • United States
    • United States District Courts. United States District Court (Columbia)
    • January 11, 2022
    ...to a general hospital that participates in the Medicare program.” Pl.'s Higher-Level Opp'n at 6. The Smith v. District of Columbia, 306 F.Supp.3d 223 (D.D.C. 2018), opinion, cited in Defendants' brief for the proposition that “[e]xpert testimony is required to explain the ‘intricacies' of o......
  • Barber v. Dist. of Columbia Gov't, No. 17-cv-620 (KBJ)
    • United States
    • United States District Courts. United States District Court (Columbia)
    • August 13, 2019
    ...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 courts to iden......
  • United States v. $215, 587.22 in U.S. Currency, Case No.17–cv–00853(CRC)
    • United States
    • U.S. District Court — District of Columbia
    • March 30, 2018
    ...Here the complaint is not conclusively time barred—it gives no indication of when the government learned of Szlavik's alleged money 306 F.Supp.3d 223transfers. In any case, the report cited by the Szlaviks concerns President Bongo's use of U.S. accounts to launder money. See Mot. Dismiss Ex......
  • Request a trial to view additional results

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