Michele Hall v. District of Columbia
2017 U.S. App. LEXIS 14888
| D.C. Cir. | 2017Background
- Michelle Hall celebrated her birthday at Cities Restaurant; Cities kept her credit card and ID on arrival. A bill for $1,104.74 was presented after the event; Hall disputed charges for two bottles she believed were free. Some guests placed cash in a bill book toward the check; Hall left temporarily to a bar across the street while the dispute was unresolved.
- Cities called 911 and reported an intoxicated female who had refused to pay; police located Hall in the bar, forced entry into a single-occupancy bathroom, handcuffed and removed her, and detained her roughly 40–45 minutes in a cruiser.
- While handcuffed in the cruiser, Hall told an officer Cities still held her credit card; an officer retrieved a receipt from Cities charging the full bill, Hall signed it, and was released.
- Hall sued the District of Columbia and officers (including Officer Alice Lee), Cities, and manager Seyhan Duru asserting § 1983 claims (false arrest, excessive force) and multiple common-law torts (assault, battery, false imprisonment, defamation, negligence, conversion, infliction of emotional distress).
- The district court dismissed several claims on the pleadings and granted summary judgment for defendants on the remaining claims. On appeal, the D.C. Circuit: affirmed summary judgment for Duru and affirmed dismissal/forfeiture of certain claims; vacated and remanded multiple rulings, holding material factual disputes and deficient pleading support several surviving claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did Cities act reasonably / in good faith in calling police (defamation, negligence, conversion)? | Cities reported felony theft without verifying Hall still owed >$1,000; record shows card was charged $935.04, cash may have covered remainder, and Hall left possessions and card with Cities. | Cities argues Hall left without paying the full bill (including tip) and thus had reason to call police; summary judgment was appropriate. | Vacated summary judgment for Cities on negligence, defamation, conversion; factual disputes (card charge, tip, cash in bill book, intent to abandon) preclude judgment. |
| Whether Officer Lee had probable cause to arrest (§ 1983 false arrest; common-law false arrest/imprisonment)? | Lee failed to ask basic questions or verify Cities’ report; complaint alleges no probable cause because card had been charged and facts were verifiable at scene. | Officer contends facts as pleaded established probable cause to arrest for theft of services; also asserts qualified immunity. | Dismissal on the pleadings vacated; complaint alleges an arrest without probable cause and qualified immunity is not clearly available on these facts — remand. |
| Whether force used was objectively unreasonable (§ 1983 excessive force; assault)? | Officers broke down bathroom door, slammed and dragged Hall, tightened cuffs despite complaints — pleaded facts show no threat or serious crime, so force was unreasonable. | Officer argued actions were justified (Hall resisted or was noncompliant; felony reported; flight risk). | Dismissal vacated for excessive force and assault claims; pleadings allege unconstitutional, unreasonable force — remand. |
| Whether factual record supports battery claim against Officer Lee (common law battery) | Discovery corroborated Hall’s account (witnesses, injuries, tightening cuffs, knee in back); material disputes exist about resistance and necessity of force. | Officer claimed Hall resisted and that use of force was reasonable; summary judgment awarded below. | Grant of summary judgment on battery vacated; record creates triable issues about whether force exceeded what was reasonable/necessary. |
Key Cases Cited
- Mpoy v. Rhee, 758 F.3d 285 (D.C. Cir.) (pleading and summary-judgment standards; view facts in plaintiff’s favor)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard for Rule 12)
- Tolan v. Cotton, 572 U.S. 650 (2014) (per curiam) (crediting plaintiff’s version of facts at summary judgment review)
- Graham v. Connor, 490 U.S. 386 (1989) (objective-reasonableness standard for excessive-force claims)
- Dunaway v. New York, 442 U.S. 200 (1979) (probable cause required for arrest vs. investigatory stop)
- Beck v. Ohio, 379 U.S. 89 (1964) (definition of probable cause)
- Illinois v. Gates, 462 U.S. 213 (1983) (totality-of-the-circumstances test for probable cause)