Eunice Graves v. Daniel Lioi
930 F.3d 307
| 4th Cir. | 2019Background
- Cleaven Williams obtained opportunity to self-surrender on a misdemeanor domestic-assault arrest warrant after his wife Veronica secured a protective order; he later murdered her and her unborn child.
- Officers Deputy Major Daniel Lioi and Major Melvin Russell had prior social/acquaintance contacts with Williams and communicated with him about surrender arrangements.
- On the evening Williams attempted to self-surrender, Central Records could not locate the physical warrant; Eastern District officers searched, found it in an officer’s patrol-car visor early the next morning, and thereafter agreed (with Williams) to a delayed self-surrender date.
- Lioi wrote two letters for Williams and exchanged texts advising him about the warrant status and to avoid his wife; Robinson alleged these and other acts constituted affirmative conduct that enabled Williams to evade arrest and created a state-created danger to Mrs. Williams.
- At the pleading stage this Court held the complaint sufficient to allege state-created-danger § 1983 claims (and denied qualified immunity). After discovery the district court granted summary judgment for the officers; the Fourth Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether officers committed "affirmative acts" that created or increased danger under the state-created-danger doctrine | Robinson: Lioi and Russell took affirmative steps (letting Williams leave, arranging delayed surrender, writing letters, advising by text, diverting/logging of warrant) that directly enabled Williams to harm his wife | Lioi/Russell: Their conduct was discretionary nonaction/omission or routine police discretion regarding warrant service; letters/texts were factual, not conspiratorial; no causal link to the murder | Held: Evidence at summary judgment did not show actionable affirmative acts or causal link; conduct characterized as omissions/discretion, so no § 1983 due process violation; summary judgment affirmed |
| Whether evidence supported a conspiracy to help Williams evade arrest | Robinson: communications, relationship, and timing show a conspiracy | Defendants: Record lacks proof—at most acquaintance and routine communications; assertions rest on speculation | Held: No admissible evidence of conspiracy; summary judgment affirmed |
| Whether officers are entitled to qualified immunity for any putative due process violation | Robinson: prior interlocutory ruling and facts show violation that was clearly established | Defendants: Even if a violation existed, law did not clearly establish that allowing self-surrender on a misdemeanor warrant violates due process | Held: Qualified immunity applies because evidence did not show a constitutional violation; alternatively, violation not clearly established in 2008 |
| Whether Maryland state-law claims (wrongful death, gross negligence, survival) survive | Robinson: state claims parallel federal theory and factual record supports liability | Defendants: Public-official immunity and lack of evidence of intentional/grossly negligent conduct or causation | Held: District court properly granted summary judgment on state claims; affirmed |
Key Cases Cited
- DeShaney v. Winnebago Cty. Dep't of Soc. Servs., 489 U.S. 189 (1989) (due process does not impose a general affirmative duty to protect individuals from private violence; state-created-danger exception originates here)
- Town of Castle Rock v. Gonzales, 545 U.S. 748 (2005) (police discretion in enforcing restraining orders and absence of a property/right to enforcement; failure to act not ordinarily a due-process violation)
- County of Sacramento v. Lewis, 523 U.S. 833 (1998) (due process protects against only the most egregious official conduct; mere negligence insufficient)
- Pinder v. Johnson, 54 F.3d 1169 (4th Cir. 1995) (state-created-danger doctrine requires direct affirmative acts that create or increase risk; mere omissions insufficient)
- Doe v. Rosa, 795 F.3d 429 (4th Cir. 2015) (reiterating narrow state-created-danger standard: affirmative acts, direct causal nexus, and limits on liability for inaction)
- Behrens v. Pelletier, 516 U.S. 299 (1996) (qualified-immunity interlocutory appeals may occur at multiple stages; different standards apply at pleadings vs. summary judgment)