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Harris v. Government of District of Columbia

United States District Court, District of Columbia

August 6, 2019




         Plaintiff Carlton J. Harris brought this action against the District of Columbia for allegedly detaining him in the D.C. jail beyond his release date. Am. Compl. [Dkt. #8] ¶ 1. Plaintiff claims that the District of Columbia, through its Department of Corrections (“DOC”), is liable for violating his Fifth Amendment due process rights under 42 U.S.C. § 1983. Id. ¶¶ 121-33. He also brings a common law claim against the District for false imprisonment. Id. ¶¶ 134-41.

         Defendant moved to dismiss the section 1983 claims under Rule 12(b)(6) of the Federal Rules of Civil Procedure for failure to state a claim upon which relief can be granted. Def.'s Mot. for Partial Dismissal [Dkt. #9] (“Def.'s Mot.”). Because the Court finds that plaintiff adequately pled claims of municipal liability based on a theory of deliberate indifference, the Court will deny defendant's motion.


         I. Factual Allegations

         Plaintiff alleges that on or about March 29, 2017, he was committed to the D.C. jail by the U.S. Marshals Service (“USMS”) pursuant to an outstanding warrant against him for failing to appear in Maryland federal court on a traffic violation. Am. Compl. ¶ 15. His detention was supposed to be an “in-transit” hold - a temporary form of commitment used by USMS to transport individuals from place to place, usually lasting “a night or two.” Id. ¶¶ 15, 17. Instead, plaintiff was not released until June 15, 2017, over two months after his initial commitment. Id. ¶ 16. According to plaintiff, the DOC did not realize the error because it failed to obtain the necessary paperwork when he was committed. Id. ¶ 18. Consequently, instead of releasing him or providing for a release hearing, as plaintiff contends the DOC should have done for an in-transit inmate, id. ¶ 19, the DOC detained him unlawfully for weeks.

         Plaintiff contends that defendant knew that overdetentions by the DOC were not uncommon at the time of his detention. Am. Compl. ¶¶ 76-77. He identifies several problematic practices, including DOC's reliance on an outdated “paper driven inmate system, ” which is prone to errors and delays, id. ¶¶ 48-71, and DOC's failure to obtain the proper commitment forms from USMS that indicate when an inmate should be picked up. Id. ¶ 105. He cites a study by an outside consultant about the DOC's detention and release processes, which reported fourteen overdetentions between 2015 and 2018, [1] id. ¶ 77, citing Resp. to Oct. 19, 2018 Min. Order at 12, United States v. Harris, No. 1:18-cr-00028 (D.D.C. Dec. 20, 2018) [Dkt. # 40-1] (“The Moss Report”), as well as prior lawsuits against the DOC for overdetentions. Id. ¶¶ 84, 102, 117, citing Smith v. District of Columbia, 306 F.Supp.3d 223 (D.D.C. 2018); Barnes v. District of Columbia, 242 F.R.D. 113 (D.D.C. 2007); Bynum v. District of Columbia, 412 F.Supp.2d 73 (D.D.C. 2006). According to plaintiff, the District was well aware of its overdetention problems “[b]ecause of litigation, D.C. Council hearings, annual oversight reports, and outside consultant reports.” Am. Compl. ¶ 76.

         II. Procedural History

         On October 17, 2018, plaintiff filed his complaint with this Court. Compl. [Dkt. #1]. He filed an amended complaint on March 18, 2019. Am. Compl. Plaintiff raises three claims: Count One alleges 42 U.S.C. § 1983 liability for overdetention, id. ¶¶ 121-26, Count Two alleges section 1983 liability “for failing to provide [plaintiff] with a release hearing, ” id. ¶¶ 127-33, and Count Three alleges false imprisonment. Id. ¶¶ 134-41.

         On April 1, 2019, the District moved for partial dismissal, seeking to dismiss Counts One and Two under Rule 12(b)(6) of the Federal Rules of Civil Procedure. Def.'s Mot. The District did not object to the false imprisonment claim in Count Three. Id. With respect to Counts One and Two, the District argued that plaintiff failed to state a claim under section 1983 because he “alleg[ed] that his over-detention was the result of an oversight . . ., rather than alleging that his over-detention was the result of an unconstitutional custom or policy, ” as the law requires. Def.'s Mem. of P. & A. in Supp. of Def.'s Mot. [Dkt. #9] (“Def.'s Mem.”) at 7. Plaintiff opposed the motion, arguing that he had in fact identified a custom or policy in the District's “deliberate indifference” to its constitutional violations. Pl.'s Opp. to Def.'s Mot. [Dkt. # 11] (“Pl.'s Opp.”) at 7-8. In its reply, the District contended that plaintiff's deliberate indifference claim was conclusory. Reply to Pl.'s Opp. [Dkt. #12] (“Def.'s Reply”) at 2-3.


         “To survive a [Rule 12(b)(6)] 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), quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). In Iqbal, the Supreme Court reiterated the two principles underlying its decision in Twombly: “First, the tenet that a court must accept as true all of the allegations contained in a complaint is inapplicable to legal conclusions.” Iqbal, 556 U.S. at 678. And “[s]econd, only a complaint that states a plausible claim for relief survives a motion to dismiss.” Id. at 679, citing Twombly, 550 U.S. at 556.

         A claim is facially plausible when the pleaded factual content “allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Iqbal, 556 U.S. at 678. “The plausibility standard is not akin to a ‘probability requirement,' but it asks for more than a sheer possibility that a defendant has acted unlawfully.” Id. A pleading must offer more than “labels and conclusions” or a “formulaic recitation of the elements of a cause of action, ” id., quoting Twombly, 550 U.S. at 555, and “[t]hreadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.” Id.

         In evaluating a motion to dismiss under Rule 12(b)(6), a court must “treat the complaint's factual allegations as true and must grant plaintiff ‘the benefit of all inferences that can be derived from the facts alleged.'” Sparrow v. United Air Lines, Inc., 216 F.3d 1111, 1113 (D.C. Cir. 2000) (internal citation omitted), quoting Schuler v. United States, 617 F.2d 605, 608 (D.C. Cir. 1979); see also Am. Nat'l Ins. Co. v. FDIC, 642 F.3d 1137, 1139 (D.C. Cir. 2011), quoting Thomas v. Principi, 394 F.3d 970, 972 (D.C. Cir. 2005). Therefore, when considering a motion to dismiss, a court must construe a complaint liberally in the plaintiff's favor. Kowal v. MCI Commc'ns Corp., 16 F.3d 1271, 1276 (D.C. Cir. 1994). Nevertheless, the court need not accept inferences drawn by the plaintiff if those inferences are unsupported by facts alleged in the complaint, nor must the court accept plaintiff's legal conclusions. Id.; see also Browning v. Clinton, 292 F.3d 235, 242 (D.C. Cir. 2002). In ruling upon a motion to dismiss for failure to state a claim, a court may ordinarily consider only “the facts alleged in the ...

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