MOLINA-AVILES v. District of Columbia
2011 U.S. Dist. LEXIS 130963
D.D.C.2011Background
- Molina-Aviles and others allege MPD Officer King, in his individual capacity, caused DWI convictions through false or improperly calibrated breath-test evidence.
- DC announced on Feb 26, 2010 that Intoxilyzer readings were inflated due to erroneous calibrations; some plaintiffs’ convictions were vacated or dismissed after the announcement.
- King headed the Impaired Driver Support Unit and allegedly calibrated/verified breath-test machines; the OME delegated calibration to MPD but failed to oversee accuracy testing.
- Plaintiffs allege MPD/OAG knew the machines were improperly calibrated yet continued to use them in court, relying on invalid scores.
- Plaintiffs sue under 42 U.S.C. § 1983 for substantive due process (Fifth Amendment) against the District and Officer King personally, seeking damages for wrongful convictions and related harms.
- Eighth Amendment claim against the District is alleged but later dismissed by the Court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether King’s conduct plausibly states a substantive due process claim. | Plaintiffs allege deliberate indifference by knowingly using false evidence. | Plaintiff must show conduct shocks the conscience; negligence not enough. | Plaintiffs’ allegations plausibly allege a due process violation. |
| Whether the claim against King is barred by qualified immunity. | King knew his methods were wrong but did not correct them; still liable. | Qualified immunity may shield if the right was not clearly established. | Cannot determine based on current record; discovery may clarify applicability. |
| Whether the Eighth Amendment claim against the District survives. | DWI confinement and related conditions constitute cruel/unusual punishment. | Eighth Amendment not implicated where Fifth Amendment due process applies. | Count IV (Eighth Amendment) is dismissed. |
| Whether the pleadings meet the standard for §1983 claims against a District policy. | District policy/indifference caused the violations. | Need show of deliberate indifference and proximate cause. | Court discusses but main disposition focuses on King’s individual claim and Eighth Amendment dismissal. |
Key Cases Cited
- Napue v. Illinois, 360 U.S. 264 (1959) (conviction obtained through known false evidence violates due process)
- County of Sacramento v. Lewis, 523 U.S. 833 (1998) (shock the conscience standard for substantive due process)
- Daniels v. Williams, 474 U.S. 327 (1986) (negligence alone not a due-process claim)
- Butera v. Dist. of Columbia, 235 F.3d 637 (D.C. Cir. 2001) (due-process standard to distinguish from tort law)
- Young v. Biggers, 938 F.2d 565 (5th Cir. 1991) (knowing manufacture of false evidence not automatically barred by qualified immunity)