Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Jones v. District of Columbia

United States District Court, District of Columbia

August 22, 2018

RICHARD JONES, et al., Plaintiff,
v.
DISTRICT OF COLUMBIA, Defendant.

          MEMORANDUM OPINION

          DABNEY L. FRIEDRICH UNITED STATES DISTRICT JUDGE.

         The plaintiff Richard Jones asserts several claims against the District of Columbia stemming from his alleged overdetention and strip search. Before the Court is the District's Motion to Dismiss the First Amended Complaint for failure to state a claim under Rule 12(b)(6) of the Federal Rules of Civil Procedure. Fed.R.Civ.P. 12(b)(6). For the reasons discussed below, the Court grants in part and denies in part the District's motion to dismiss.

         I. BACKGROUND

         On December 7, 2015, Jones attended a hearing at the federal courthouse and was ordered released from the custody of the Department of Corrections. First Amended Compl. ¶¶ 128, 129, 135, Dkt. 12. Following the hearing, the Marshals transferred Jones to Department of Corrections staff who then transported Jones to the D.C. Jail. Id. At the D.C. Jail, Jones allegedly told the receiving and discharge staff that he had been ordered released, but the staff could not find a release order. Id. ¶¶ 130, 131. Thus, staff subjected Jones to a strip-search and returned him to his cell in the general population. Id. ¶¶ 130, 131, 137. Jones alleges that he was held in the D.C. Jail for several hours. Id. ¶¶ 132. In the alternative, Jones alleges that he was held more than five hours from the moment the Marshals transferred him to the Department of Corrections transport officers at the federal courthouse. Id. ¶ 133.

         Jones further alleges that the Department of Corrections “routinely” and “systematically” holds detainees past their release times. Id. ¶¶ 13, 117. In particular, Jones claims that the Department of Corrections' practice of not releasing inmates until it obtains inmates' paper release dispositions leads to the unconstitutional overdetention of individuals who have been ordered released. Id. ¶ 41. Jones also contends that the Department of Corrections “does not reliably” follow its own policy that requires transporting defendants who have been ordered released to D.C. General Hospital where they are not subjected to strip searches, absent individualized suspicion. Id. ¶ 37.

         Jones asserts constitutional claims based on his overdetention and strip search. Additionally, he asserts common law claims for false arrest and invasion of privacy.

         II. LEGAL STANDARD(S)

         In evaluating a motion to dismiss, the Court must treat the complaint's “factual allegations as true and must grant the plaintiff the benefit of all inferences that can be derived from the facts alleged.” Center for Responsible Science v. Gottlieb, 311 F.Supp.3d 5, 8 (D.D.C. 2018) (internal quotation marks and alterations omitted). “The Court need not accept as true, however, a legal conclusion couched as a factual allegation, nor an inference unsupported by the facts set forth in the Complaint.” Id. (internal quotation marks omitted).

         To survive a motion to dismiss, a complaint “must contain sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (internal quotation marks omitted). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged. Id. (internal citation omitted). A “complaint attacked by a Rule 12(b)(6) motion to dismiss does not need detailed factual allegations.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007). But the factual allegations in the complaint “must be enough to raise a right to relief above the speculative level.” Id.

         Here, Jones attempts to state several claims for municipal liability. To determine whether Jones has stated a claim, the Court must conduct a two-step inquiry: “First, the court must determine whether the complaint states a claim for a predicate constitutional violation. Second, if so, then the court must determine whether the complaint states a claim that a custom or policy of the municipality caused the violation.” Baker v. District of Columbia, 326 F.3d 1302, 1306 (D.C. Cir. 2003) (internal citations omitted).

         III. ANALYSIS

         Jones argues that his overdetention and strip search violated his Fourth and Fifth Amendment rights.[1] He also asserts common law claims for false arrest and invasion of privacy.

         A. Constitutional Claims Stemming from Jones's Overdetention

         Jones first argues that his overdetention constituted an unreasonable seizure under the Fourth Amendment. The Fourth Amendment guarantees the “right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures.” U.S. Const. amend. IV. “A seizure triggering the Fourth Amendment's protections occurs when a person's freedom of movement is terminated or restrained, either by physical force or a show of authority.” See Barnes v. District of Columbia, 793 F.Supp.2d 260, 273-74 (D.D.C. 2011) (internal quotation marks omitted). But here, Jones was already in custody when he was ordered released. In other words, Jones's “freedom of movement had already been terminated.” Id. (internal citations omitted). And Jones did not allege or provide any factual support in his complaint suggesting that his overdetention involved a fresh seizure, which would warrant a Fourth Amendment analysis. See id. Moreover, “[m]ost courts that have considered overdetention claims have agreed that they are properly channeled through the Due Process Clause” ...


Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.