Hamid v. United States
247 F. Supp. 3d 131
| D.D.C. | 2017Background
- On March 30, 2014, Capitol Police Officer Seth Carll stopped Osman Hamid’s taxicab after observing erratic driving and swerving; Carll requested Hamid’s D.C. license and checked its validity over the radio.
- Radio checks of WALES/NCIC allegedly indicated Hamid’s D.C. commercial license was disqualified/invalid; Carll arrested Hamid for driving without a valid license.
- While in custody, officers discovered an apparently valid Australian license on Hamid’s person; charges were dropped and Hamid was released the same night and later treated at a hospital for injuries he claimed arose from the arrest.
- Hamid sued under the Federal Tort Claims Act for false arrest and false imprisonment, contending Carll lacked probable cause and seeking discovery of the WALES/NCIC reports under Rule 56(d) and the best-evidence rule.
- The Government moved for judgment on the pleadings or summary judgment, submitting Carll’s sworn declaration describing the observed traffic conduct, the radio confirmation that the D.C. license was invalid, and the subsequent arrest and release.
- The court found Carll had probable cause based on what was communicated to him over the radio, denied Hamid’s Rule 56(d) discovery request as inadequate under Convertino, granted summary judgment for the United States, but stayed final judgment until May 1, 2017 to allow Hamid to file a substantive opposition conforming to local rules.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the stop and arrest were supported by probable cause | Hamid: Officer lacked probable cause or articulable suspicion; radio reports must be produced to challenge validity | U.S.: Officer observed traffic violations and was told over radio the D.C. license was invalid, which provided probable cause | Court: Probable cause existed based on facts known to Officer Carll (observed driving + radio report) |
| Admissibility/necessity of WALES/NCIC reports (best evidence) | Hamid: Calls for production of WALES/NCIC reports and invokes best-evidence rule | U.S.: Probative fact is what was communicated to the arresting officer, not underlying reports | Court: Best-evidence rule inapplicable; what matters is officer’s knowledge from radio, not the WALES/NCIC documents |
| Rule 56(d) discovery request adequacy | Hamid: Needs limited discovery of documents/witnesses regarding disqualification notice | U.S.: Request was speculative and insufficient to defeat summary judgment | Court: Hamid’s affidavit fails Convertino’s three-factor test; Rule 56(d) discovery denied |
| Effect of Australian license found in custody | Hamid: Existence of valid Australian license undermines validity of arrest | U.S.: Hamid did not present that license during the stop, so it did not affect probable cause at the time | Court: Irrelevant to probable cause because it was not shown to Officer Carll during the stop |
Key Cases Cited
- Anderson v. Liberty Lobby, 477 U.S. 242 (summary judgment standard requiring no genuine dispute of material fact)
- Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (nonmovant must do more than create metaphysical doubt)
- Convertino v. U.S. Dep’t of Justice, 684 F.3d 93 (requirements for a Rule 56(d) affidavit)
- United States v. Southerland, 486 F.3d 1355 (reliance on WALES information can establish objective probable cause)
- Devenpeck v. Alford, 543 U.S. 146 (probable cause assessed by facts known to arresting officer at time of arrest)
- United States v. Catlett, 97 F.3d 565 (definition of probable cause under D.C. Circuit)