Muhammad v. District of Columbia
881 F. Supp. 2d 115
D.D.C.2012Background
- Plaintiff Muhammad, proceeding pro se, sues Officer Santos and the District under 42 U.S.C. § 1983 and common law for an incident at the Georgia Avenue Day festival on June 23, 2007.
- Santos, on a bicycle, allegedly yelled for Muhammad to move to the sidewalk and, allegedly without provocation, pushed him causing injury.
- Santos is in the Metropolitan Police Department; the District is sued for municipal liability under § 1983.
- Plaintiff asserts four counts: § 1983 claim against Santos, § 1983 against the District, common-law assault, and IIED.
- The District and Santos move for summary judgment; the court grants in part and denies in part, preserving a common-law assault claim as battery.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Santos is entitled to qualified immunity on the §1983 claim | Muhammad asserts a rights violation by Santos | Santos acted reasonably; rights not clearly established | Qualified immunity applicable; no clearly established right |
| Whether the District may be held liable under §1983 for a municipal policy | District was deliberately indifferent to training and supervision | Insufficient evidence of deliberate indifference; existing training | No municipal §1983 liability; judgment for District |
| Whether the common-law assault claim survives summary judgment | Santos used force to push Muhammad off street | Dispute over degree of force; action may be battery | Assault claim survives; IIED claim dismissed |
| Whether the IIED claim is viable | Extreme conduct by Santos | Not extreme beyond decency | IIED claim dismissed |
Key Cases Cited
- Saucier v. Katz, 533 U.S. 194 (2001) (two-step qualified-immunity framework; governs whether right was clearly established)
- Harlow v. Fitzgerald, 457 U.S. 800 (1982) (establishes threshold for qualified immunity)
- Wilson v. Layne, 526 U.S. 603 (1999) (qualified immunity turns on objective reasonableness of actions)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (summary judgment standard; evidence must show genuine issues of material fact)
- City of Canton v. Harris, 489 U.S. 378 (1989) (policy or practice must show deliberate indifference to rights)
- Pearson v. Callahan, 555 U.S. 223 (2009) (courts may choose which prong of qualified-immunity analysis to address first)
- Youngbey v. March, 676 F.3d 1114 (2012) (illustrates consideration of clearly established right in context)