Campbell v. District of Columbia
245 F. Supp. 3d 78
| D.D.C. | 2017Background
- Officers Newton and Croson (MPD Vice Unit) observed Campbell on a D.C. street and followed him into Big Ben liquor store without lights/siren; Newton wore a vest marked “POLICE.”
- Newton grabbed Campbell inside the store to conduct an investigatory stop; a multi‑angle surveillance video records Campbell struggling, Newton pulling on Campbell’s scarf, and officers ultimately subduing and arresting him.
- Officers recovered suboxone film strips from Campbell’s jacket lining and cash from a store trash can; Campbell was charged with assault on an officer and possession, but prosecutors later nolle prossed the charges.
- Campbell sued under 42 U.S.C. § 1983 (unlawful seizure, false arrest, excessive force, malicious prosecution) and D.C. common law (assault, battery, false imprisonment/prosecution, IIED); discovery completed and defendants moved for summary judgment.
- The court viewed the surveillance video and held: genuine dispute exists as to the lawfulness of the initial investigatory stop (denying summary judgment on that claim), but probable cause supported the subsequent arrest and force used was not excessive; common‑law claims likewise dismissed except for the initial stop.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Lawfulness of initial investigatory stop (reasonable suspicion) | Campbell: officers lacked reasonable, articulable suspicion (he did not display or toss anything; was merely walking to store) | Newton/Croson: high‑crime area, observed display/tossing motion, and flight toward store gave reasonable suspicion | Denied summary judgment for defendants — disputed facts preclude finding reasonable suspicion as a matter of law |
| Validity of arrest for Assault on Police Officer (probable cause) | Campbell: no probable cause; he did not know they were police and was not violent (officer’s punch claim disputed) | Defendants: video shows active physical resistance (pushing, pulling away) and officers were identifiable; resistance gave probable cause for APO | Summary judgment for defendants — video establishes probable cause for APO arrest |
| Excessive force under § 1983 (Fourth Amendment) | Campbell: force used (neck push, scarf pull, takedown) was excessive and caused injury | Defendants: force was objectively reasonable given Campbell’s size, active resistance, and safety concerns; no significant injury shown | Summary judgment for defendants — force not objectively unreasonable under Graham factors |
| Common‑law torts (false arrest, battery, IIED, malicious prosecution) | Campbell: torts flow from unlawful stop/arrest and force | Defendants: probable cause and reasonable force are affirmative defenses; nolle prosequi does not negate probable cause defense | Summary judgment for defendants on these claims (probable cause/privilege defeats them); only initial stop claim survives |
Key Cases Cited
- Terry v. Ohio, 392 U.S. 1 (establishes reasonable‑suspicion standard for investigatory stops)
- Brown v. Texas, 443 U.S. 47 (walking away in high‑crime area insufficient alone for reasonable suspicion)
- Scott v. Harris, 550 U.S. 372 (courts may rely on video evidence to resolve factual disputes at summary judgment)
- Graham v. Connor, 490 U.S. 386 (Fourth Amendment reasonableness test for excessive force)
- Muehler v. Mena, 544 U.S. 93 (distinct Fourth Amendment standards apply to different seizures/searches in one encounter)
- United States v. Castle, 825 F.3d 625 (D.C. Cir. guidance that flight/walking away in high‑crime area often insufficient for reasonable suspicion)
- Duhart v. United States, 589 A.2d 895 (D.C. Ct. App. decision refusing to credit innocent explanations as sufficient to create reasonable suspicion)