Barnes v. District of Columbia
2011 U.S. Dist. LEXIS 67425
| D.D.C. | 2011Background
- The case concerns overdetentions and blanket strip searches of inmates released from the District of Columbia jails following court orders or sentence expirations.
- A 2008 settlement in Bynum v. District of Columbia required reforms, including an Inmate Processing Center and separation of court-ordered releases from those held in custody.
- Despite Bynum, the DOC continued to experience delays and long processing times, with reports of thousands of overdetentions during the early class period.
- The District implemented measures over time (courthouse release program, centralized Records Office processing, staff training, discrepancy reports, and sentence-computation software) beginning in 2007–2008.
- A 10 p.m. cut-off ordinance (the 10 p.m. rule) allegedly caused overnight overdetentions by barring releases after 10 p.m., and was later found unconstitutional as applied.
- Plaintiffs seek relief under 42 U.S.C. § 1983 for Fourth and Fifth Amendment violations related to overdetentions and Fourth Amendment strip searches.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did overdetentions violate the Fourth Amendment? | Barnes argues overdetentions were unconstitutional seizures. | DC claims no fresh seizure occurred and detention complied with release processes. | No; Fourth Amendment not violated because detainees were already in custody when ordered released. |
| Did overdetentions violate the Fifth Amendment due process right to prompt release? | Barnes asserts deliberate indifference and unreasonable delays after release orders. | District argues reforms reduced delays and no policy of inaction; expert says releases are efficient. | Yes for period Sept 1, 2005 to Dec 31, 2006; questions of material fact remain for Jan 1, 2007 to Feb 25, 2008; later period denied. |
| Is the District liable for overdetentions caused by the 10 p.m. cut-off rule? | Rule caused mandatory overnight detentions leading to violations. | Rule served inmate welfare and was not per se unconstitutional. | Yes; the 10 p.m. cut-off rule caused violations; District liable for those overdetentions. |
| Are strip searches of court returns entitled to release a Fourth Amendment violation by the District? | blanket strip searches without individualized suspicion are unconstitutional. | Policies are reasonable under certain circuits; security needs justify searches. | Yes; blanket strip searches without individualized suspicion are unreasonable; District liable. |
| Can the District be held liable under Monell for the strip searches and overdetentions? | Deliberate indifference or a continuing custom caused constitutional violations. | Any reforms show non-deliberate conduct; no actionable policy for all periods. | Yes for the strip searches; Yes for the first 16 months of overdetentions; disputed for later period. |
Key Cases Cited
- Collins v. City of Harker Heights, 503 U.S. 115 (1992) (due process and seizures analysis for termination of freedom of movement)
- Monell v. Dep't of Soc. Servs., 436 U.S. 658 (1978) (municipal liability for official policy or custom)
- Berry v. Baca, 379 F.3d 764 (9th Cir. 2004) (no bright-line rule for delays in post-release processing)
- Brass v. County of Los Angeles, 328 F.3d 1192 (9th Cir. 2003) (limits of administrative delays in detention contexts)
- McLaughlin v. County of Riverside, 500 U.S. 44 (1991) (48-hour rule framework in probable cause context; delays in detention must be reasonable)
- Bull v. City and County of San Francisco, 595 F.3d 964 (9th Cir. 2010) (en banc on strip searches of arrestees absent individualized suspicion)
- Powell v. Barrett, 541 F.3d 1298 (11th Cir. 2008) (en banc discussion on arrestee strip searches without individualized suspicion)