Buie v. District of Columbia, Civil Action No. 2016-1920

Background

Darrell Best was an MPD officer with prior disciplinary history (sustained 2009 misconduct finding, demotion) who also served as pastor of a church he founded.
On December 3, 2014, Best (in uniform, with service weapon) took 17‑year‑old Jaquia Buie to dinner, then drove her to MPD headquarters and attempted to sexually assault/rape her in a CSB office; Buie resisted and later reported the assault.
Best was investigated, prosecuted in federal court, pleaded guilty to charges including sexual abuse of a minor and was sentenced to 18 years in prison.
Buie filed suit (Sept. 2016) against Best and the District of Columbia asserting § 1983 claims (Fourth and Fifth Amendment) against the District (Monell) and multiple common‑law tort claims against the District and Best.
The District moved for summary judgment on the § 1983 municipal liability claims (Counts I–II) and on several common‑law counts (III–VIII).
The Court granted summary judgment for the District on the § 1983 Monell claims (finding no triable causal link between MPD policy/inaction and Best’s crime) but denied without prejudice the motion as to state common‑law claims pending clarification of the Court’s supplemental‑jurisdictional posture.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether MPD’s failure to train/supervise on sexual misconduct supports Monell liability	MPD lacked a clear written sexual‑misconduct policy and training, creating deliberate indifference that caused Best’s constitutional violations	MPD provided recruit and ongoing EEO/harassment training; no pattern/causal link to Best’s off‑duty criminal conduct	Court: No. Even assuming training gaps, plaintiff failed to show the deficiency was the moving force causing Best’s crime; summary judgment for District granted
Whether MPD’s decision not to terminate Best in 2009 amounts to deliberate indifference	Retaining/demoting Best after prior complaints showed conscious disregard of risk to vulnerable women	MPD investigated, referred matters to U.S. Attorney, disciplined/demoted Best; no evidence of policy of inaction	Court: No. MPD took action (referrals, demotion); failure‑to‑terminate theory fails as deliberate indifference
Whether MPD maintained a pattern of inadequate investigations/discipline for sexual misconduct	Scattered examples show systemic, shoddy investigations and tolerance of misconduct	Examples are irregular, many resulted in discipline or prosecution referrals; no concentrated pattern meeting Monell standard	Court: No. Plaintiff’s incidents were too fragmented to show a systemic policy of deliberate indifference
Whether Chief Lanier’s decision to detail Best to CSB (headquarters) is a policymaker act creating municipal liability	Detailing Best to headquarters by a final policymaker proximately caused the constitutional violation	Argument raised first at summary judgment; no evidence the administrative detail authorized or caused Best’s criminal conduct	Court: No. Theory improperly raised late and lacks causation; summary judgment for District granted
Disposition of pendent common‑law claims and jurisdiction	Plaintiff seeks to keep tort claims in federal court	District seeks summary judgment on torts; argues federal claims against District are dismissed so supplemental jurisdiction should be declined	Court: Denied without prejudice as to Counts III–VIII — Court dismissed the federal Monell claims and declined to decide pendent jurisdiction without further briefing; District may refile addressing § 1367 issues

Key Cases Cited

Monell v. Dep’t of Soc. Servs. of City of New York, 436 U.S. 658 (municipal liability requires an official policy or custom)
City of Canton v. Harris, 489 U.S. 378 (failure‑to‑train standard: deliberate indifference and causal nexus)
Connick v. Thompson, 563 U.S. 51 (pattern normally required to show deliberate indifference)
Bd. of Cty. Comm’rs of Bryan Cty. v. Brown, 520 U.S. 397 (limits on liability for hiring/retention; ‘plainly obvious’ standard)
Pembaur v. Cincinnati, 475 U.S. 469 (single final policymaker decision can constitute municipal policy)
Torres v. Madrid, 141 S. Ct. 989 (definition of seizure under Fourth Amendment)
City of Oklahoma City v. Tuttle, 471 U.S. 808 (causation and municipal policy principles)
Praprotnik v. City of St. Louis, 485 U.S. 112 (final policymaker authority limits)
Hurd v. District of Columbia, 997 F.3d 332 (D.C. Cir. standard on deliberate indifference and pattern requirement)
Shekoyan v. Sibley Int’l, 409 F.3d 414 (federal courts ordinarily decline supplemental jurisdiction after dismissal of federal claims)
Anderson v. Liberty Lobby, 477 U.S. 242 (summary judgment standard)
Jackson v. District of Columbia, 327 F. Supp. 3d 52 (examples on investigatory practices and municipal liability analysis)