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Gaskins v. United States

United States District Court, District of Columbia

May 26, 2016

Alvin Gaskins, Plaintiff,
v.
United States of America, Defendant.

          MEMORANDUM OPINION AND ORDER

          Amit P. Mehta United States District Judge.

         I. INTRODUCTION

         In this suit brought under the Federal Tort Claims Act, Plaintiff Alvin Gaskins alleges that Defendant United States negligently and falsely imprisoned him when it failed to release him from jail until fourteen days after his conviction was vacated. Defendant has moved for partial summary judgment, not at this point contesting liability, but rather arguing that Plaintiff’s damages are capped by Texas state law, which operates in this case to determine the extent of Defendant’s liability. Defendant asserts that the Tim Cole Act, which is a Texas law that compensates certain wrongfully imprisoned persons at a rate of $80, 000 per year, applies to Plaintiff. Under the Act, Defendant argues, Plaintiff’s damages for two weeks of wrongful detention are approximately $3, 100. Accordingly, the narrow question presented by Defendant’s motion is whether the Tim Cole Act applies in this case.

         The court concludes that the Tim Cole Act does not apply and denies Defendant’s Motion for Partial Summary Judgment.

         II. BACKGROUND

         A. Factual Background

         A jury convicted Plaintiff of conspiring to distribute narcotics; he was sentenced to 262 months of imprisonment. See United States v. Gaskins, 690 F.3d 569, 576 (D.C. Cir. 2012). On April 30, 2012, after he had served approximately eight years, the Court of Appeals reversed Plaintiff’s conviction, finding that the evidence presented at trial was insufficient to sustain his conviction. Id.; Def.’s Statement of Material Facts not in Genuine Dispute [hereinafter Undisputed Material Facts], ECF No. 18, ¶ 3; Pl.’s Resp. to Def.’s Statement of Material Facts, ECF No. 20, at 9. The Court of Appeals also ordered the trial court to enter a judgment of acquittal, which occurred the next day, May 1, 2012. Undisputed Material Facts ¶¶ 3-4.

         The federal Bureau of Prisons (“BOP”) did not, however, release Plaintiff immediately. It allowed two weeks to pass before releasing him on May 15, 2012. Id. ¶ 5. At the time his conviction was vacated, Plaintiff was incarcerated at a BOP facility in Texas. Compl., ECF No. 1, ¶ 7.

         B. Procedural Background

         Plaintiff filed this action under the Federal Tort Claims Act (“FTCA”), 28 U.S.C. § 1346(b)(1), alleging that the United States is liable for his over-detention under the common law torts of negligence and false imprisonment. See Compl. ¶¶ 4, 8-12, 15-21. Plaintiff sought compensatory damages, litigation costs, and any other appropriate relief. Id. at 3.

         At a status hearing held on September 4, 2015, Defendant asserted that Texas law-which applies in this case for purposes of determining the extent of Defendant’s liability under the FTCA-contains a statutory cap on the damages available to Plaintiff. The court suggested, and the parties agreed, to brief that discrete issue on a partial motion for summary judgment, which is now before the court. See Def.’s Mot. for Partial Summ. J., ECF No. 18 [hereinafter Def.’s Mot.].[1]

         III. DISCUSSION

         Plaintiff brings suit under Section 1346(b)(1) of the FTCA, which makes the United States liable

for injury or loss of property, or personal injury or death caused by the negligent or wrongful act or omission of any employee of the Government while acting within the scope of his office or employment, under circumstances where the United States, if a private person, would be liable to the claimant ...

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