Amobi v. District of Columbia Department of Corrections
410 U.S. App. D.C. 338
| D.C. Cir. | 2014Background
- Derrick Brown, an inmate, assaulted correctional officer Amobi during a June 4, 2006 incident at DC Jail.
- Amobi and his wife sued DC, DOC, and several Jail officials for multiple torts and constitutional violations.
- Amobi was arrested and charged based on jail officials’ statements and incident reports, without the precursors of an independent exculpatory investigation.
- Investigation at the Jail allegedly omitted exculpatory evidence and a purported inmate interview was claimed to exist but was ultimately fictitious.
- Arrest led to a criminal prosecution that stalled, then collapsed after Brown testified and admitted planning the ruse; Amobi was acquitted.
- Arbitration under Amobi’s union CBA eventually ordered reinstatement with back pay, but the District delayed formal reinstatement; suit followed in 2008.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Probable cause for false arrest and liability | Amobi asserts lack of probable cause and argues officers’ and officials’ misrepresentations. | District contends officers’ observations and statements provided probable cause or reasonable basis. | Material issues of fact on probable cause remain; summary judgment reversed for false arrest claims against certain jail officials. |
| Personal liability for false arrest due to withheld exculpatory evidence | Officials knowingly omitted exculpatory facts to mislead arresting officer. | Defendants deny deliberate concealment affecting probable cause. | Reversed: genuine issues of material fact on whether officials acted with bad faith and caused the false arrest. |
| Malicious prosecution and due process | Prosecution continued without probable cause and was tainted by fraud/bad faith. | Defendants argue immunity and lack of malice or suppression of evidence. | Merits of the malicious prosecution claims reserved for trial; constitutional malice in prosecution found for some defendants. |
| Defamation and statute of limitations | Defamatory statements tolled the limitations period. | Continuous defamation did not toll the one-year limit for defamation. | Defamation claims time-barred; continuation did not toll accrual; constitutional defamation moot. |
| IIED viability | Conduct was extreme and outrageous, causing severe distress. | District argues no extreme or outrageous conduct established. | Summary judgment reversed; jury to determine if conduct was extreme and outrageous. |
Key Cases Cited
- Scott v. District of Columbia, 101 F.3d 748 (D.C. Cir. 1996) (Fourth Amendment false arrest analysis; proximity of claims to policy and custom)
- Carney v. American University, 151 F.3d 1090 (D.C. Cir. 1998) (Constitutional false arrest and related claims; absence of probable cause and policy considerations)
- Shulman v. Miskell, 626 F.2d 173 (D.C. Cir. 1980) (Statute of limitations and tolling considerations in false arrest/malicious prosecution)
- Pitt v. District of Columbia, 491 F.3d 494 (D.C. Cir. 2007) (Malicious prosecution framework; malice and probable cause considerations)
- Viner v. Friedman, 33 A.2d 631 (D.C. 1943) (Malice presumed from lack of probable cause in malicious prosecution)
- Smith v. District of Columbia, 399 A.2d 213 (D.C. 1979) (Informed reporting and false arrest liability; duty to disclose material facts)