Clark v. Computer Science Corporation
958 F. Supp. 2d 208
D.D.C.2013Background
- Clark sues Insight Global, Kforce, and CSC for wrongful arrest/false imprisonment related to laptops.
- IT contractors for the EPA; Clark occasionally tested inoperable laptops at home; CSC issued property pass.
- February 2011: Clark takes home two laptops; terminated shortly after; attempts to return property follow.
- DHS later reports the laptop as stolen; location traced to Clark; Clark returns laptops in June 2011.
- DHS informs Clark of arrest warrant; Clark surrenders and is detained briefly; he is acquitted in a DC Superior Court trial.
- Court grants defendants' Rule 12(b)(6) motions to dismiss; denies summary judgment motions as moot; denies remand.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Claim viability for false arrest | Clark alleges defendants knowingly made false reports. | No report by CSC/Insight Global; only negligent conduct by Kforce alleged. | Claims dismissed; no plausible false arrest facts. |
| Malicious prosecution elements | Defendants acted with malice in instigating prosecution. | No malice or lack of probable cause pleaded. | Dismissed; insufficient facts of malice/probable cause absence. |
| Intentional infliction of emotional distress | Defendants’ conduct was extreme and outrageous. | Conduct not extreme or outrageous enough. | Dismissed; not within extreme/outrageous standard. |
| Negligent infliction of emotional distress | Relationship implicates emotional well-being; negligence caused distress. | No direct injury or zone of danger; no relationship underpinning claim. | Dismissed; insufficient facts of physical injury or relevant relationship. |
| Negligent hiring/training/retention | Employer failed to train/supervise/retain adequately; caused harm. | Insufficient facts showing negligent hiring/training/retention. | Dismissed; no facts showing proximate causation or improper hiring/supervision. |
Key Cases Cited
- Sparrow v. United Air Lines, Inc., 216 F.3d 1111 (D.C. Cir. 2000) (treat allegations as true but require plausible grounds for relief)
- Twombly, 550 U.S. 544 (S. Ct. 2007) (pleading must show plausible claim, not just speculative)
- Iqbal, 556 U.S. 662 (S. Ct. 2009) (pleading standard requires plausible entitlement to relief)
- DeWitt v. District of Columbia, 43 A.3d 291 (D.C. 2012) (malice and probable cause framework for false arrest/malicious prosecution in DC)
- Magwood v. Giddings, 672 A.2d 1083 (D.C. 1996) (probable cause as defense to false arrest claim)
- Smith v. District of Columbia, 399 A.2d 213 (D.C. 1979) (false arrest requires more than reporting an offense absent bad faith)
- Vessels v. District of Columbia, 531 A.2d 1016 (D.C. 1987) (false reporting element requires knowingly malicious report)
- Hedgepath v. Whitman Walker Clinic, 22 A.3d 789 (D.C. 2011) (negligent infliction requires specific emotional distress relationship)
- McNeill v. District of Columbia, 613 A.2d 940 (D.C. 1992) (zone-of-danger and physical injury requirements for NEID)
- Williams v. Baker, 572 A.2d 1062 (D.C. 1990) (emotional distress elements under DC law)
- Beyene v. Hilton Hotels Corp., 815 F. Supp. 2d 235 (D.D.C. 2011) (negligent hiring and retention standards)
- Dormu v. District of Columbia, 795 F. Supp. 2d 7 (D.D.C. 2011) (negligent hiring/retention principles in DC context)
- Phelan v. City of Mount Rainier, 805 A.2d 930 (D.C. 2002) (DC negligence standards relevant to the claims)
- St. Paul Mercury Indemnity Co. v. Red Cab Co., 303 U.S. 283 (S. Ct. 1938) (jurisdictional and removal considerations at issue)
- Kopff v. World Research Group, LLC, 298 F. Supp. 2d 50 (D.D.C. 2003) (jurisdiction and amendment-related futility considerations)