Bradshaw v. District of Columbia
2012 D.C. App. LEXIS 159
| D.C. | 2012Background
- Bradshaw was arrested by MPD Officer Jones in a club on Oct 24, 2004 after a club bouncer told Jones Bradshaw needed to leave; Jones stopped Bradshaw when she attempted to re-enter the club.
- Bradshaw alleged false arrest/imprisonment and constitutional deprivation under §1983; the District and Jones moved for summary judgment.
- Trial court granted summary judgment, holding Jones had probable cause based on the bouncer’s information to remove Bradshaw.
- On appeal, the District argued the bouncer’s tip gave probable cause for attempted assault; Bradshaw disputed the reliability and content of what the bouncer said.
- The DC Court of Appeals reversed the prior decision, finding material issues remained about what the bouncer actually told Jones and whether that information supported probable cause or a reasonable belief of lawfulness.
- Remand was ordered for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Jones had probable cause to arrest Bradshaw based on the bouncer’s information. | Bradshaw contends no authority or reliable basis to arrest. | District argues bouncer’s report was reasonably trustworthy indicating an offense. | No; genuine issue of material fact remains about what bouncer told Jones. |
| Whether the bouncer’s statement about Bradshaw fighting another patron was properly established as a basis for probable cause. | Bradshaw asserts the bouncer did not clearly convey such a report. | District relies on the bouncer’s tip as basis for arrest. | Not clearly established; jury must determine what was communicated and its impact. |
| Whether the arrest could be justified by good faith belief under Murphy/Enders standards. | Bradshaw disputes the officer’s good faith reliance on the bouncer’s tip. | Officer could reasonably believe the information supported arrest. | Disputed; cannot decide as a matter of law; issues must go to jury. |
| Whether the case should be remanded for trial rather than resolution on summary judgment. | Facts about communications should be resolved by fact-finder. | Summary judgment appropriate if evidence supports probable cause. | Remand appropriate; summary judgment improper. |
Key Cases Cited
- Murphy v. District of Columbia, 631 A.2d 34 (D.C.1993) (probable cause/good faith standard for arrest; mixed question of law and fact)
- Murphy v. District of Columbia, 635 A.2d 929 (D.C.1993) (Murphy II; perspective of officer in evaluating information)
- Enders v. District of Columbia, 4 A.3d 457 (D.C.2010) (probable cause defense; objective inquiry on information available at the scene)
- Funchess v. United States, 677 A.2d 1019 (D.C.1996) (probable cause may be based on informant’s tip if reliable under totality-of-circumstances)
- District of Columbia v. Minor, 740 A.2d 523 (D.C.1999) (informant tips and reliability in calculating probable cause)