On February 23, 2006, four men incarcerated at the District of Columbia Jail 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 Bynum v. District of Columbia, 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, the Bynum settlement did not require that those practices stop. According to the plaintiffs, the unlawful practices of at issue in the Bynum case had been reconstituted, such that injunctive relief was now necessary.

The Barnes plaintiffs, represented by private counsel, including some of the same attorneys as in Bynum, sought damages and declaratory and injunctive relief. Shortly after filing, they moved for the certification of a two classes: one of people who had been overdetained and another of people who had been been subjected to an illegal strip search.

The District moved to dismiss, or in the alternative, for summary judgment. That motion was denied on March 26, 2007, by District Judge Royce C. Lamberth. 242 F.R.D. 113. Commenting that the case was "virtually identical" to the Bynum case, Judge Lamberth also certified both classes the plaintiffs requested as "hybrid" Rule 23(b)(3) classes, which allowed the plaintiffs to pursue both injunctive relief and monetary damages.

On January 20, 2011, the plaintiffs filed a third amended complaint. 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, Judge Lamberth ruled on both parties' summary judgment motions. He 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 Judge Lamberth held that 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 Judge Lamberth stayed the decertification order was appropriate, but only as of when the plaintiffs’ moved for the stay. 924 F. Supp. 2d 103. Leading up to the trial, both parties filed various motions regarding discovery and evidence that the court addressed. 924 F. Supp. 2d 74.

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.

From 2013 to approximately 2019, the parties continued to report to the court on the progress of payments to class members. However, there has been no action on the docket since August of 2019 and the case appears to be closed.

Dan Dalton - 04/05/2007
Jessica Kincaid - 02/14/2016
Jonah Hudson-Erdman - 09/07/2021


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