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Case Name Smith v. District of Columbia CJ-DC-0003
Docket / Court 1:15-cv-00161-ABJ ( D.D.C. )
Additional Docket(s) 2014 CA 007278 B  [ 14-7278 ]  Trial Court (DC)
2014 CA 007278 B  [ 14-7276 ]  Trial Court (DC)
State/Territory District of Columbia
Case Type(s) Criminal Justice (Other)
Case Summary
On November 14, 2014, a man who had been left in jail for twenty-three days after his court-ordered release date filed this lawsuit in the Superior Court for the District of Columbia. The plaintiff sued the District of Columbia, the D.C. Department of Corrections, and several employees of the D.C ... read more >
On November 14, 2014, a man who had been left in jail for twenty-three days after his court-ordered release date filed this lawsuit in the Superior Court for the District of Columbia. The plaintiff sued the District of Columbia, the D.C. Department of Corrections, and several employees of the D.C. Department of Corrections under 42 U.S.C. § 1983 and common law. The plaintiff’s release was ordered on March 18, 2014, but he was not released until April 10, 2014. He alleged that his overdetention was illegal false imprisonment, constituted negligence on the part of the defendants, and violated his due process rights under the Fifth and Fourteenth Amendments. Represented by private counsel, the plaintiff sought compensatory damages, punitive damages, and attorneys’ fees. On February 2, 2015, the defendants removed the case to the United States District Court for the District of Columbia. The case was assigned to Judge Amy Berman Jackson.

On February 9, 2015, the Department of Corrections filed a motion to dismiss because, as an agency within the D.C. government, it could not be a party to any lawsuit. On February 27, the parties filed a stipulation that dismissed the Department of Correction from the case.

On August 14, 2015, the warden of the D.C. Jail filed a motion to dismiss for failure to state a claim, arguing that the official-capacity claims against defendant Smith are duplicative of his claims against the District of Columbia and that the complaint did not allege any viable individual-capacity claims against him. On December 15, the court granted this motion, and the warden was dismissed as a defendant. 149 F.Supp.3d 128.

On February 1, 2016, the case was referred to Magistrate Judge Alan Kay for mediation. Initial attempts at mediation were unsuccessful.

On April 21, 2016, the plaintiff filed an amended complaint, adding two individual defendants and an additional claim against the District of Columbia. Then, on May 11, the plaintiff moved for discovery costs and fees, alleging that the defendants had claimed that certain documents did not exist and then failed to provide the plaintiff with them once the plaintiff found out that they did exist. The case was randomly reassigned to Magistrate Judge Robinson to decide on this motion. On December 6, Magistrate Judge Robinson granted the motion in part and denied it in part: the District of Columbia was precluded from using those documents, and the plaintiff was granted $18,428.30 in fees and costs. 319 F.R.D. 40. (Judge Jackson would later reduce this amount down to $15,579.90. 249 F.Supp.3d 106.)

In December 2016 and January 2017, both sides sought summary judgment; after the parties alleged different versions of the facts, the court denied both motions as moot on February 21, 2017.

On March 31, 2017, the defendants filed another motion for partial summary judgment, as did the plaintiff two weeks later. Nearly a year later, on March 30, 2018, the court granted both of these motions in part and denied them both in part. The constitutional claims and the false imprisonment claims against the two individual defendants were dismissed, leaving only the negligence claim at issue for those defendants. The false imprisonment and negligence claims against the District of Columbia were decided in favor of the plaintiff, as was part of the due process claim. For all other claims against the District of Columbia, the plaintiff was denied summary judgment. The District of Columbia was granted summary judgment as to the plaintiff's negligent supervision and training claim and part of the plaintiff's due process claim. 2018 WL 1568878.

On April 20, 2018, the court referred this case, with consent of the parties, to Magistrate Judge G. Michael Harvey for mediation. As of June 2018, the case is ongoing. A settlement conference is scheduled for July 11, 2018.

Rebecca Strauss - 06/22/2018


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Issues and Causes of Action
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Issues
Constitutional Clause
Due Process
Defendant-type
Corrections
General
Discharge & termination plans
Failure to supervise
Failure to train
Over/Unlawful Detention
Pattern or Practice
Record-keeping
Records Disclosure
Plaintiff Type
Private Plaintiff
Causes of Action 42 U.S.C. § 1983
Defendant(s) District of Columbia
Plaintiff Description A man left in jail for twenty-three days after his court-ordered release date.
Class action status sought No
Class action status granted No
Filed Pro Se No
Prevailing Party Plaintiff
Public Int. Lawyer No
Nature of Relief None yet
Source of Relief None yet
Filing Year 2015
Case Ongoing Yes
Docket(s)
1:15−cv−00161−ABJ (D.D.C.)
CJ-DC-0003-9000.pdf | Detail
Date: 06/05/2018
Source: PACER [Public Access to Court Electronic Records]
General Documents
Complaint [ECF# 1]
CJ-DC-0003-0001.pdf | Detail
Date: 02/02/2015
Source: PACER [Public Access to Court Electronic Records]
Memorandum Opinion [ECF# 26] (149 F.Supp.3d 128) (D.D.C.)
CJ-DC-0003-0003.pdf | WESTLAW| LEXIS | Detail
Date: 12/15/2015
Source: PACER [Public Access to Court Electronic Records]
First Amended Complaint [ECF# 36]
CJ-DC-0003-0002.pdf | Detail
Date: 04/21/2016
Source: PACER [Public Access to Court Electronic Records]
Memorandum Opinion [ECF# 54] (319 F.R.D. 40) (D.D.C.)
CJ-DC-0003-0004.pdf | WESTLAW| LEXIS | Detail
Date: 12/06/2016
Source: PACER [Public Access to Court Electronic Records]
Memorandum Opinion and Order [ECF# 74] (249 F.Supp.3d 106) (D.D.C.)
CJ-DC-0003-0005.pdf | WESTLAW| LEXIS | Detail
Date: 04/06/2017
Source: PACER [Public Access to Court Electronic Records]
Memorandum Opinion [ECF# 86] (2018 WL 1568878) (D.D.C.)
CJ-DC-0003-0006.pdf | WESTLAW | Detail
Date: 03/30/2018
Source: PACER [Public Access to Court Electronic Records]
Judges Jackson, Amy Berman (D.D.C.)
CJ-DC-0003-0003 | CJ-DC-0003-0005 | CJ-DC-0003-0006 | CJ-DC-0003-9000
Robinson, Deborah A. (D.D.C.) [Magistrate]
CJ-DC-0003-0004
Plaintiff's Lawyers Akulian, David (District of Columbia)
CJ-DC-0003-0001 | CJ-DC-0003-0002 | CJ-DC-0003-9000
Klaproth, Jesse Colin (District of Columbia)
CJ-DC-0003-9000
Klaproth, Brendan James (District of Columbia)
CJ-DC-0003-0001 | CJ-DC-0003-0002 | CJ-DC-0003-9000
Defendant's Lawyers Addo, Michael K (District of Columbia)
CJ-DC-0003-9000
Coppock, Akua Damali (District of Columbia)
CJ-DC-0003-9000
Cullen, Alicia Marie (District of Columbia)
CJ-DC-0003-9000
DeBerardinis, Robert A. Jr. (District of Columbia)
CJ-DC-0003-9000

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