Clark v. District of Columbia
241 F. Supp. 3d 24
| D.D.C. | 2017Background
- Edward Clark was investigated by MPD Detective Steven Manley in a PCP distribution probe; Manley allegedly misassociated a phone number and showed Clark’s photo to a cooperating witness.
- An arrest warrant issued March 2014; Clark was arrested July 17, 2014, detained, released on GPS supervision, and criminal proceedings followed.
- The government moved to dismiss the criminal charge without prejudice on December 30, 2014; the court granted the motion on December 31, 2014.
- Clark sued Manley (individually and officially) and the District of Columbia, alleging negligent infliction of emotional distress (NIED), malicious prosecution, and Fourth Amendment violations (Section 1983).
- Defendants moved to dismiss (and sought summary judgment as to the NIED claim against the District). The Court assessed pleadings under Rule 12(b)(6).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether NIED claim is plausibly pled against Manley/the District | Clark: arresting/ investigating relationship (arrestee/arrester) necessarily implicated his emotional well‑being and Manley negligently performed duties | Defs: no special relationship or undertaking that necessarily implicates emotional well‑being; §12‑309 notice problem (as to District) | Court: Dismisses NIED — no special relationship/undertaking shown; did not reach §12‑309 question |
| Whether malicious prosecution claim is plausibly pled | Clark: prosecution based on false/erroneous information from Manley; alleges lack of probable cause and malice | Defs: insufficient pleading of malice and that criminal case terminated in Clark’s favor | Court: Denies dismissal — pleadings sufficiently allege lack of probable cause, malice (inference), and that dismissal without prejudice plausibly reflects innocence at this stage |
| Whether Fourth Amendment §1983 claim survives (and whether Manley has qualified immunity) | Clark: Manley made false statements/reckless accusations that led to arrest/indictment and detention | Defs: Grand jury indictment creates prima facie probable cause; Manley entitled to qualified immunity | Court: Denies dismissal — plaintiff alleged facts sufficient to rebut presumption of probable cause and to avoid resolving qualified immunity at pleading stage |
| Procedural posture: scope of relief/next steps | N/A | N/A | Court GRANTS in part and DENIES in part Defs’ motion: NIED dismissed; malicious prosecution and Fourth Amendment claims proceed |
Key Cases Cited
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (established plausibility pleading standard)
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard; inferences required to be reasonable)
- Hedgepeth v. Whitman Walker Clinic, 22 A.3d 789 (D.C. en banc) (explains special‑relationship test for NIED)
- DeWitt v. District of Columbia, 43 A.3d 291 (defines elements of malicious prosecution in D.C.)
- Brown v. Carr, 503 A.2d 1241 (D.C. Ct. App.) (termination must reflect on the merits to be "favorable")
- Moore v. Hartman, 571 F.3d 62 (grand jury indictment gives prima facie probable cause; can be rebutted)
- Amobi v. D.C. Dep’t of Corrections, 755 F.3d 980 (probable cause can be rebutted where indictment produced by wrongful conduct)
- Ashcroft v. al‑Kidd, 563 U.S. 731 (qualified immunity framework; clearly established law)
- Harlow v. Fitzgerald, 457 U.S. 800 (qualified immunity standard)