Hedgpeth v. Rahim
213 F. Supp. 3d 211
| D.D.C. | 2016Background
- On March 2, 2015, Jonathan Hedgpeth, after drinking, was approached by MPD officers Ammar Rahim and Matthew Rider near U Street following reports of someone pushing people; Hedgpeth had separately greeted a former coworker, Marcus Lee.
- Officers testified Hedgpeth was loud, slurred his speech, refused to provide an arm for handcuffing, and had earlier pushed a bystander; Lee testified Hedgpeth was coherent with him and may have been feigning intoxication.
- Rahim moved to arrest Hedgpeth; during an apprehension the officer performed a takedown, and Hedgpeth fell forward, striking a metal-grated storefront window and suffering a serious head laceration and post-concussive injuries.
- Hedgpeth sued Rahim and Rider under 42 U.S.C. § 1983 (false arrest and excessive force) and asserted state-law claims for assault/battery and false arrest; Defendants moved for summary judgment asserting qualified immunity.
- The District Court found (viewing evidence in plaintiff’s favor where appropriate) that officers had objectively reasonable grounds to believe probable cause existed for misdemeanor offenses (public intoxication, assault, disorderly conduct, affray) and that Rahim’s takedown did not violate clearly established law; summary judgment for defendants was granted on federal claims.
- The Court declined to exercise supplemental jurisdiction over the remaining state-law claims and dismissed them without prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| False arrest — probable cause | Hedgpeth contends officers lacked probable cause because his contact with others was friendly (e.g., "buddy punch") and one witness (Lee) said it was innocent | Officers argue they had probable cause for misdemeanors: public intoxication, simple assault, disorderly conduct, affray based on slurred speech, loud/obnoxious behavior, report of pushing a stranger, and refusal to comply | Court: Defendants entitled to qualified immunity on false-arrest claim — officers reasonably could believe probable cause existed |
| Excessive force (Fourth Amendment) | Hedgpeth says Rahim used gratuitous violence by slamming his head into a grate during a takedown, causing serious injury | Rahim says he performed a routine takedown after Hedgpeth refused compliance and that the head injury was an accidental result of the fall; Rider used no force | Court: On facts viewed favorably to plaintiff, reasonableness is close but no clearly established law makes a takedown in these circumstances unlawful; Rahim entitled to qualified immunity |
| Qualified immunity standard | Hedgpeth argues officers should have known the takedown was excessive and unlawful | Defendants argue that, given noncompliance, intoxication, and potential risk, a takedown was within established precedent permitting some force | Court: Applied the two-prong test; even if constitutional violation debatable, law was not clearly established such that a reasonable officer would have known the takedown was unlawful |
| Supplemental jurisdiction over state claims | Hedgpeth seeks to keep state assault/battery and false-arrest claims in federal court | Defendants did not press jurisdictional dismissal but argued for judgment on merits via summary judgment | Court: Declined to exercise supplemental jurisdiction after dismissing federal claims; state claims dismissed without prejudice (tolling preserved) |
Key Cases Cited
- Saucier v. Katz, 533 U.S. 194 (procedural two-step for qualified immunity)
- Pearson v. Callahan, 555 U.S. 223 (court may decide qualified immunity prongs in either order)
- Graham v. Connor, 490 U.S. 386 (standard for excessive-force claims under the Fourth Amendment)
- Hunter v. Bryant, 502 U.S. 224 (reasonableness standard for qualified immunity where officers may be mistaken)
- Illinois v. Gates, 462 U.S. 213 (probable cause as a practical, common-sense determination)
- Johnson v. District of Columbia, 528 F.3d 969 (D.C. Cir. — gratuitous force clearly unconstitutional)
- Scott v. District of Columbia, 101 F.3d 748 (D.C. Cir. — takedown of erratic/intoxicated suspect found reasonable)
- Wardlaw v. Pickett, 1 F.3d 1297 (summary-judgment standard in qualified-immunity context)