Grimes Ex Rel. Estate of Grimes v. District of Columbia, 417 App. D.C. 241

Karl Grimes, a juvenile detainee, died at Oak Hill Juvenile Detention Facility in Nov 2005.
Patricia Grimes, acting as his mother and representative, sued the District of Columbia for damages.
Plaintiff claimed deliberate indifference under the Eighth Amendment, Monell liability, and negligent hiring/training/supervision under DC tort law.
District court granted summary judgment for the District; Grimes’s motion to strike/disqualify the Attorney General was denied as moot.
Grimes appealed after district court denied her disqualification motion; the panel vacated and remanded to address the conflict issue before ruling on merits.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Conflict-of-interest before dispositive motion	Grimes argued Nickles’s conflict tainted proceedings	District claimed no disqualifying conflict	Vacate summary judgment and remand to decide disqualification first
Effect of discovery and expert needs on summary judgment	Grimes needed discovery/experts to oppose	District showed absence of evidence for essential elements	Remand to allow proper discovery and determine merits aeon remand progress
Rule 56/evidence standards applied to unopposed motion	Rule 56 requires record-based evaluation, not concession	District treated lack of opposition as admitted facts	District must independently assess record; cannot treat unopposed motion as conceded

Celotex Corp. v. Catrett, 477 U.S. 317 (U.S. 1986) ( burdens shifting; movant need show absence of evidence supporting plaintiff’s claim)
Farmer v. Brennan, 511 U.S. 825 (U.S. 1994) (deliberate indifference standard in Eighth Amendment cases)
Monell v. New York City Dept. of Social Services, 436 U.S. 658 (U.S. 1978) (municipal liability for official policy or custom; Monell)
Adickes v. Kress & Co., 398 U.S. 144 (U.S. 1970) (claims burden on moving party; production vs. evidence)