Ford v. District of Columbia
Civil Action No. 2013-1960
| D.D.C. | Aug 16, 2016Background
- Ford sued the District of Columbia and Detectives Paprcka and Bovino under 42 U.S.C. § 1983 for a warrantless intrusion into her apartment.
- On May 9, 2012, the Detectives served a grand jury subpoena at Ford’s apartment, entering without a warrant or consent after finding the door ajar and hearing a baby crying.
- Detectives testified they announced, knocked, and then entered to address a potential emergency; Ford contends there were no exigent circumstances.
- Ford asserted Fourth Amendment violations, and the District was alleged to be liable for inadequate training, investigation, and discipline regarding warrantless entries.
- Both sides moved for summary judgment; the court analyzed qualified immunity for the Detectives and Monell municipal liability for the District.
- The court denied the Detectives’ summary judgment on qualified immunity and granted Ford’s cross-motion; it granted the District’s summary judgment and denied Ford’s cross-motion on the Monell claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether exigent circumstances justified warrantless entry | Ford | Paprcka/Bovino | No exigent circumstances; entry unreasonable |
| Whether the Detectives are entitled to qualified immunity | Ford | Paprcka/Bovino | Qualified immunity not warranted |
| Whether Ford’s invasion of privacy and trespass claims survive | Ford | Paprcka/Bovino | Liability established against detectives |
| Whether the District is liable under Monell for failure to train/supervise regarding warrantless entries | Ford | District | District not liable; no deliberate indifference shown |
Key Cases Cited
- Brigham City v. Stuart, 547 U.S. 398 (2006) (emergency aid exception to warrantless entry)
- Mincey v. Arizona, 437 U.S. 385 (1978) (need for immediate aid; true immediacy required)
- Groh v. Ramirez, 540 U.S. 551 (2004) (warrantless searches presumptively unreasonable)
- Brigham City v. Stuart, 547 U.S. 398 (2006) (emergency aid exception to warrantless entry)
- United States v. Williams, 354 F.3d 497 (6th Cir. 2003) (objective test for exigent circumstances)
- Anderson v. Creighton, 483 U.S. 635 (1987) (clearly established law for qualified immunity (objective reasonableness))
- Saucier v. Katz, 533 U.S. 194 (2001) (two-step approach to qualified immunity)
- Pearson v. Callahan, 555 U.S. 223 (2009) (modifies Saucier by allowing flexible order of inquiries)
- Monell v. Department of Social Servs. of N.Y., 436 U.S. 658 (1978) (municipal liability for official policy)
- City of Canton v. Harris, 489 U.S. 378 (1989) (deliberate indifference standard for failure to train/supervise)