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Hall v. District of Columbia

United States District Court, District of Columbia

April 12, 2018

WILLIAM JARTA HALL, Plaintiff,
v.
DISTRICT OF COLUMBIA, et al., Defendants.

          MEMORANDUM OPINION

          COLLEEN KOLLAR-KOTELLY United States District Judge

         Plaintiff William Jarta Hall brings this lawsuit against the District of Columbia (“the District”) and Frederick Onoja, an officer of the District's Metropolitan Police Department (“MPD”). Plaintiff alleges that Officer Onoja assaulted and falsely arrested him. Plaintiff also alleges that, after his arrest, Officer Onoja fabricated evidence incriminating Plaintiff for crimes that he did not commit. Plaintiff asserts several common law causes of action, as well as claims under the Fourth and Fifth Amendments.

         Presently before the Court is Defendants' [32] Motion for Judgment on the Pleadings as to Plaintiff's Fifth Amendment Claim, and the District's Partial Motion for Summary Judgment. The District moved for summary judgment on Plaintiff's constitutional claims against it on the grounds that Plaintiff has not adduced sufficient evidence of the District's municipal liability. Both Defendants also moved for judgment on the pleadings on Plaintiff's Fifth Amendment fabrication of evidence claim on the grounds that it “merges” with Plaintiff's Fourth Amendment claims.

         Upon consideration of the pleadings, [1] the relevant legal authorities, and the record as a whole, the Court shall DENY both motions. The District's Motion for Summary Judgment is DENIED because it is MOOT. After this motion was filed, Plaintiff voluntarily dismissed his municipal liability constitutional claim against the District (Count 8). Defendants' Motion for Judgment on the Pleadings as to Plaintiff's Fifth Amendment claim (Count 7)-which, as a result of Plaintiff's voluntary dismissal of his constitutional claims against the District, is now argued only on behalf of Defendant Onoja-is also DENIED. Defendant Onoja concedes that a fabrication of evidence claim can be actionable under the Fifth Amendment. However, he contends that, on the particular facts of this case, such a claim “merges” with Plaintiff's Fourth Amendment claims because all of these claims are premised on the execution of Plaintiff's arrest. As discussed in more detail below, the Court disagrees with Defendant's interpretation of the relevant case law and his characterization of Plaintiff's claims. Because the alleged fabrication of evidence that underlies Plaintiff's Fifth Amendment due process claim is separate and distinct from his arrest, the Court finds that “merger” is not necessary or appropriate.

         I. BACKGROUND

         Plaintiff alleges that on October 27, 2015, he was attacked without justification by Officer Onoja. Am. Compl., ECF No. 15, ¶ 7. Plaintiff claims that Officer Onoja grabbed him from behind without provocation and proceeded to beat him. Id. To cover up this unjustified use of force, Plaintiff alleges, Officer Onoja arrested him on “trumped up” charges. Id. ¶¶ 26-29. Officer Onoja then allegedly “swore out a statement falsely claiming that [Plaintiff] assaulted him and threatened him and provided false evidence to the U.S. Attorney who then charge and prosecuted [Plaintiff] for [assault on a police officer] and threats . . . to kidnap an officer.” Id. The government ultimately dismissed all charges against Plaintiff. Id. ¶ 31.

         In his Amended Complaint, Plaintiff asserted causes of actions for common law assault and false arrest against Defendants Onoja and the District. Id. ¶¶ 69-76, 83-90. He also asserted claims against Defendant Onoja under 42 U.S.C. § 1983 for violation of Plaintiff's Fourth Amendment rights (false arrest and use of unreasonable force) and Fifth Amendment rights (fabrication of evidence). Id. ¶¶ 77-82, 91-98. Finally, Plaintiff asserted a municipal liability claim under Section 1983 against the District. Id. ¶¶ 99-102.

         The pending motions were filed after the discovery period closed. They have been fully briefed and are ripe for resolution.

         II. LEGAL STANDARD

         Pursuant to Federal Rule of Civil Procedure 12(c), a party may move for judgment on the pleadings “[a]fter the pleadings are closed-but early enough not to delay trial.” The standard for reviewing a motion for judgment on the pleadings is virtually identical to that applied to a motion to dismiss under Rule 12(b)(6). See Haynesworth v. Miller, 820 F.2d 1245, 1254 (D.C. Cir. 1987), abrogated on other grounds by Hartman v. Moore, 547 U.S. 250 (2006); Jung v. Ass'n of Am. Med. Colleges, 339 F.Supp.2d 26, 36 (D.D.C. 2004) (“[T]he standard of review for motions for judgment on the pleadings under Rule 12(c) of the Federal Rules of Civil Procedure is essentially the same as that for motions to dismiss under Rule 12(b)(6).”). “The court is limited to considering facts alleged in the complaint, any documents attached to or incorporated in the complaint, matters of which the court may take judicial notice, and matters of public record.” Baumann v. D.C., 744 F.Supp.2d 216, 222 (D.D.C. 2010).

         III. DISCUSSION

         There are two motions before the Court, but one need only be addressed briefly. The District has filed a Motion for Summary Judgment on Plaintiff's constitutional claims against it, arguing that Plaintiff has not adduced sufficient evidence of the District's municipal liability. The District's Motion for Summary Judgment has been rendered moot. After that motion was filed, the parties agreed to dismiss Plaintiff's municipal liability claim (Count 8) against the District with prejudice. See Joint Praecipe of Partial Dismissal Only as to Municipal Liability Claim (Count 8), ECF No. 34. That claim is DISMISSED, and the District's Motion for Summary Judgment is DENIED as MOOT.

         Accordingly, all that is left for the Court to consider at this time is Defendant Onoja's Motion for Judgment on the Pleadings on Plaintiff's Fifth Amendment claim (Count 7). At the threshold, the Court notes that Plaintiff makes several arguments in his opposition to this motion that Defendant Onoja does not appear to dispute. First, Plaintiff argues that he has pled sufficient facts to put Defendant on notice of his Fifth Amendment claim. Pl.'s Opp'n at 2-3. Defendant concedes this point. Def.'s Reply at 3. Second, Plaintiff argues that fabrication of evidence claims are generally cognizable under the Fifth Amendment. Pl.'s Opp'n at 4. Defendant concedes this as well. Def.'s Reply at 3 (“Defendant Onoja does not contend that a fabrication of evidence claim can never be pursued under the Fifth Amendment.”). Finally, Plaintiff argues that an individual need not have been convicted on the basis of false evidence in order to be able to state a due process claim for fabrication of evidence. Pl.'s Opp'n at 5-6. Defendant has not argued that Plaintiff's Fifth Amendment claim must be dismissed because Plaintiff was not ultimately convicted. Regardless, although it is not aware of any authority from this Circuit on the issue, the Court agrees with Plaintiff that the “majority view” is that conviction is not required. See Cole v. Carson, 802 F.3d 752, 768-71 (5th Cir. 2015), cert. granted, judgment vacated sub nom. Hunter v. Cole, 137 S.Ct. 497 (2016) (discussing case law from each circuit); Black v. Montgomery Cty., 835 F.3d 358, 369 (3d Cir. 2016) (“a stand-alone fabrication of evidence claim can proceed if there is no conviction”).

         Defendant's argument is narrow: he argues that Plaintiff's Fifth Amendment claim should be dismissed on the pleadings only because it “merges” with Plaintiff's Fourth Amendment claims. Defs.' Mot. at 5. More specifically, Defendant argues that “Plaintiff's Fifth Amendment claim . . . is properly analyzed under the Fourth Amendment, as the claim is predicated ...


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