University of Michigan Law School
Civil Rights Litigation Clearinghouse
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Case Name Barnes v. District of Columbia JC-DC-0005
Docket / Court 1:06-cv-00315 ( D.D.C. )
State/Territory District of Columbia
Case Type(s) Jail Conditions
Special Collection Strip Search Cases
Case Summary
On February 23, 2006, on behalf of themselves and all others similarly situated, plaintiffs filed this 42 U.S.C. § 1983 class action suit in the District Court for the District of Columbia. The plaintiffs claimed that D.C. Jail officials violated their Fourth, Fifth, and Eighth Amendment rights in ... read more >
On February 23, 2006, on behalf of themselves and all others similarly situated, plaintiffs filed this 42 U.S.C. § 1983 class action suit in the District Court for the District of Columbia. The plaintiffs claimed that D.C. Jail officials violated their Fourth, Fifth, and Eighth Amendment rights in detaining them beyond their release dates and violated their Fourth and Fifth Amendment rights for conducting blanket strip searches.

The Barnes case followed a nearly identical class action lawsuit styled Bynum v. District of Columbia, Civil Action No. 02-956 (RCL), JC-DC-0004 in this Clearinghouse. The Bynum case resulted in a $14 million settlement.

The Barnes plaintiffs alleged that while the District agreed to stop its practices of overdetention and strip searches, and did so in the context of the Bynum settlement. The Final Approval Order in the Bynum case did not require that those practices stop. The Barnes plaintiffs alleged that despite the Bynum settlement, the unlawful practices of overdetention and strip searches had been reconstituted, such that injunctive relief was now necessary.

The Barnes plaintiffs, who were represented by some of the same attorneys as in Bynum, sought damages and declaratory and injunctive relief.

The District moved to dismiss, or in the alternative, for summary judgment. That motion was denied on March 26, 2007, by the District Court (Judge Royce C. Lamberth). The Court certified an Overdetention Class and a Strip Search class, just as it had done in the Bynum case.

On January 20, 2011, the plaintiffs filed their third amended complaint for individual money damages and class injunctive relief and jury demand. Following the close of liability discovery, the parties cross-motions for summary judgment were granted in part and denied in part.

On June 24, 2011, the District Court (Judge Lamberth) ruled on both parties' summary judgment motions. Judge Lamberth granted the plaintiffs summary judgment on their claims related to the strip searches and on the District’s liability for overdetentions from 2005 to 2006. Judge Lamberth granted the District summary judgment on its claims of overdetentions from 2008 to the present. 793 F. Supp. 2d 260 (D.D.C. 2011).

Then, the plaintiffs asked for leave to file another amended complaint. The parties moved again for summary judgement. But on December 7, 2011, the District Court (Judge Lamberth) held that 1) the court would not grant the plaintiffs leave to amend their complaint and that the court would not entertain further motions for summary judgment. Judge Lamberth also addressed additional discovery issues, how the issue of general damages would be tried, and that the class would be decertified to try the issue of special damages. 278 F.R.D. 14 (D.D.C. 2011).

After Judge Lamberth had decertified the special damages class, the plaintiffs had moved to stay the decertification order and to make the stay of decertification order retroactive to date of that order. On February 19, 2013, the District Court (Judge Lamberth) stayed the decertification order was appropriate, but only as of when the plaintiffs’ moved for the stay. Leading up to the trial, both parties filed various motions regarding discovery and evidence that the court addressed.

In March 2013, there was a week-long jury trial. Afterward, the District moved for judgment as a matter of law, which was denied. But on March 11, the jury found that the plaintiffs were unconstitutionally overdetained at the D.C. Jail between 2007 and 2008, but that the District wasn't liable; the jury didn't find evidence of "deliberate indifference" to the inmates' rights. Because Judge Lamberth had already granted the plaintiffs summary judgment on claims related to the strip searches and on the city's liability for overdetentions from 2005 to 2006, the parties moved for the case to be referred to mediation and the litigation stayed.

On November 4, 2013, the parties reached a settlement agreement, which the Court approved on March 18, 2014. The District agreed to provide monetary compensation for each plaintiff, based on the length of time they were "overdetained" and for qualifying strip searches. The District also agreed to pay a total of $6.2 million to the plaintiffs, the class members, and to cover costs and attorney's fees. The court retained jurisdiction to enforce the terms of the agreement.

As of February 2016, the District had filed two status reports with the court on the payments to the plaintiffs.

Dan Dalton - 04/05/2007
Jessica Kincaid - 02/14/2016


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Issues and Causes of Action
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Issues
Affected Gender
Female
Male
General
Over/Unlawful Detention
Search policies
Strip search policy
Type of Facility
Government-run
Causes of Action 42 U.S.C. § 1983
Defendant(s) District of Columbia
Plaintiff Description Persons overdetained by the DC Dept. of Corrections, beginning 9/1/05; persons scheduled to be released by DC DOC and subjected to strip search or visual body cavity search on return from court, without individualized suspicion.
Indexed Lawyer Organizations None on record
Class action status sought Yes
Class action status granted Yes
Prevailing Party Plaintiff
Public Int. Lawyer No
Nature of Relief Attorneys fees
Damages
Source of Relief Litigation
Settlement
Form of Settlement Court Approved Settlement or Consent Decree
Order Duration not on record
Case Closing Year 2014
Case Ongoing Unknown
Case Listing JC-DC-0004 : Bynum v. District of Columbia (D.D.C.)
Additional Resources
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Case Studies After Decision: Implementation of Judicial Decrees in Correctional Settings
Written: Oct. 01, 1977
By: M. Kay Harris & Dudley P. Spiller (Temple University)
Citation: (1977)
[ Detail ] [ PDF ]

  Jail Strip-Search Cases: Patterns and Participants
http://law.duke.edu/journals/lcp
By: Margo Schlanger (Washington University in St. Louis)
Citation: 71 Law & Contemp. Problems 65 (2008)
[ Detail ] [ External Link ]

Docket(s)
1:06-cv-00315-RCL (D.D.C.) 02/11/2016
JC-DC-0005-9000.pdf | Detail
PACER [Public Access to Court Electronic Records]
General Documents
Complaint for Individual Money Damages and Class Injunctive Relief and Jury Demand 02/23/2006
JC-DC-0005-0008.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Class Action - Second Amended Complaint for Individual Money Damages and Class Injunctive Relief And Jury Demand 05/24/2006
JC-DC-0005-0002.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Memorandum Opinion 03/26/2007 (242 F.R.D. 113) (D.D.C.)
JC-DC-0005-0001.pdf | WESTLAW| LEXIS | Detail
Third Amended Complaint for Individual Money Damages and Class Injunctive Relief and Jury Demand 01/20/2011
JC-DC-0005-0007.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Memorandum Opinion and Order 06/24/2011 (793 F.Supp.2d 260) (D.D.C.)
JC-DC-0005-0003.pdf | WESTLAW| LEXIS | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Memorandum and Order 12/07/2011 (D.D.C.)
JC-DC-0005-0009.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Memorandum Opinion 09/28/2012 (289 F.R.D. 1) (D.D.C.)
JC-DC-0005-0006.pdf | WESTLAW| LEXIS | Detail
Memorandum Opinion (Resolving Parties' Motions in Limine) 02/14/2013 (924 F.Supp.2d 74) (D.D.C.)
JC-DC-0005-0004.pdf | WESTLAW| LEXIS | Detail
Document Source: Westlaw
Memorandum Opinion and Order (Regarding Class Notice and Decertification of Special Damages Class) 02/19/2013 (924 F.Supp.2d 103) (D.D.C.)
JC-DC-0005-0005.pdf | WESTLAW| LEXIS | Detail
Document Source: Westlaw
Class Action Settlement Agreement 11/04/2013
JC-DC-0005-0010.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Judges Lamberth, Royce C. (D.D.C., FISC)
JC-DC-0005-0001 | JC-DC-0005-0003 | JC-DC-0005-0004 | JC-DC-0005-0005 | JC-DC-0005-0006 | JC-DC-0005-0009 | JC-DC-0005-9000
Monitors/Masters None on record
Plaintiff's Lawyers Brown, Stacey R. (California)
JC-DC-0005-9000
Claiborne, William Charles III (District of Columbia)
JC-DC-0005-0002 | JC-DC-0005-0007 | JC-DC-0005-0008 | JC-DC-0005-9000
Estuar, Paul J. (California)
JC-DC-0005-9000
Litt, Barrett S. (California)
JC-DC-0005-0010 | JC-DC-0005-9000
Robinson, Ralph Douglas (Virginia)
JC-DC-0005-0010 | JC-DC-0005-9000
Defendant's Lawyers Baker, Denise J. (District of Columbia)
JC-DC-0005-9000
Efros, Ellen A. (District of Columbia)
JC-DC-0005-9000
Graham, Grace (District of Columbia)
JC-DC-0005-9000
Parsons, Keith David (District of Columbia)
JC-DC-0005-9000
Saindon, Andrew J. (District of Columbia)
JC-DC-0005-9000
Other Lawyers None on record

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