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Antoine L. Wilkins v. District of Columbia

July 24, 2012

ANTOINE L. WILKINS, PLAINTIFF,
v.
DISTRICT OF COLUMBIA, DEFENDANT.



The opinion of the court was delivered by: Rudolph Contreras United States District Judge

MEMORANDUM OPINION

While being held at the District of Columbia Central Detention Facility ("D.C. Jail"), Plaintiff Antoine Wilkins was stabbed by another detainee. He brought this action against the District of Columbia, asserting (among other claims) that the stabbing resulted from the District's negligence. On July 26 and 27, 2010 the Honorable Henry H. Kennedy, Jr. presided over a trial in this case. The following day, pursuant to Federal Rule of Civil Procedure 50(a), Judge Kennedy entered judgment as a matter of law in favor of the District. Mr. Wilkins now moves for reconsideration of that ruling as to his negligence claim.*fn1

I. BACKGROUND

Viewing the evidence in the light most favorable to Mr. Wilkins, Judge Kennedy summarized the facts of this case as follows:

[A]t 9:15 a.m. on the morning of June 14th, 2005, George Foreman, an inmate at the D.C. Jail held on charges of first-degree murder, received a pass to go to the jail's law library unaccompanied. The pass Foreman received . . . has no signature indicating that Foreman arrived at the library. No one from the library called Foreman's housing unit to report that he had not arrived. So no corrections officer[s] were alerted [that] they should search for him.

According to plaintiff's expert witness, this failure to monitor inmate movements violated national standards for the operation of jails.

At 11:18 the same morning, the plaintiff received a pass to go to the jail's mental health unit. After exiting his housing unit, he saw Foreman talking to a corrections officer. Wilkins kept walking, but by turning he was able to see Foreman enter a mop closet. He also thereafter saw Foreman shake hands with another inmate. As the two men approached an area at the top of an escalator, Foreman stabbed Wilkins nine times with a knife.

During the presentation of the evidence there was testimony about mop closets like the one Foreman entered into prior to stabbing Wilkins. These closets are for storage of cleaning supplies. There was testimony that inmates had hidden contraband-that is, items that are not permitted at the jail-in the mop closets.

These closets are supposed to be locked at all times, other than when the jail is being cleaned each afternoon. But there was evidence from which the jury could infer that all inmates except those who did not have jobs cleaning in the jail had access to them.

According to the plaintiff's expert witness, keeping mop closets locked at times when the general inmate population is permitted to be in the vicinity of the closets is in accordance with national standards of care for the operation of detention facilities.

Trial Tr. at 4--5, July 28, 2010.*fn2

Based on this evidence and pursuant to Rule 50(a), which permits a court to grant judgment against a party if "the court finds that a reasonable jury would not have a legally sufficient evidentiary basis to find for the party on" the issue in question, FED. R. CIV. P. 50(a)(1), Judge Kennedy granted judgment to the District. Assessing Mr. Wilkins's negligence claim-the only claim at issue on this motion-Judge Kennedy concluded that Mr. Wilkins had failed to present sufficient evidence to allow a jury to conclude that the District could have foreseen Mr. Foreman's violent attack. Mr. Wilkins now seeks the court's reconsideration.

II. LEGAL STANDARD

Mr. Wilkins moves under Federal Rules of Civil Procedure 59(a) and 59(e). The court will consider this motion under the latter rule, because "[r]egardless of the way a party characterizes a motion, a post-judgment filing challenging the correctness of the judgment falls within the ...


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