Rawlings v. District of Columbia
2011 U.S. Dist. LEXIS 124994
D.D.C.2011Background
- Haskel, off-duty MPD officer, shot and killed 14-year-old DeOnte Rawlings during a pursuit in a DC alley, with Clay accompanying in an off-duty capacity.
- Officers testified they pursued Rawlings’ minibike without notifying MPD and without identifying themselves as police; Clay retrieved a gun and rode in the truck.
- Plaintiff alleges constitutional and common-law claims: assault and battery, negligence, conspiracy to commit assault and battery, and negligent training/supervision.
- Disputed facts include whether Rawlings possessed or fired a gun and whether the officers’ actions were privileged or negligent; a third eyewitness corroborates parts of the officers’ narrative.
- Court previously denied summary judgment on Haskel’s assault and battery and on related §1983 claims against Haskel and Clay; this opinion addresses monopolies on remaining claims (Count III, Count VII) and conspiracy (Count VI).
- Court ultimately granted in part and denied in part the defendants’ summary judgment motion on Counts VI, III, and VII, with conspiracy surviving and the other claims resolved in the defendants’ favor.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether intracorporate conspiracy bars liability | Clay and Haskel acted as MPD officers; shared employment shield conspiracy. | Intracorporate conspiracy doctrine prevents conspiracy liability among same-entity employees. | Intracorporate doctrine does not shield here; defendants acted with independent personal stake and outside routine employment. |
| Whether Clay and Haskel conspired to assault and battery | Circumstantial evidence shows agreement before/after shooting; jury should infer conspiracy. | No explicit agreement; actions were private and not part of MPD duties. | Genuine issues of material fact exist; conspiracy claim survived summary judgment. |
| Whether Clay is liable for assault and battery | Clay assisted or encouraged the assault or participated in unlawful conduct. | Clay did not fire or engage in assault; no aiding/abetting evidence; no liability. | Summary judgment granted for Clay; no assault and battery liability. |
| Whether the District is liable for negligence (common law) for actions of its officers | Special relationship or training deficiency led to harm through negligent action. | No distinct negligence theory supports liability beyond the assault/battery standard; no causal link shown. | Negligence claims against DC dismissed; no viable common-law negligence against the District. |
| Whether negligent training and supervision under §1983 is established | MPD failures show deliberate indifference; prior shootings demanded training/counseling. | Insufficient evidence of a policy of deliberate indifference; past incidents do not prove widespread failure. | Monell/§1983 negligent training claim dismissed; no evidence of pervasive policy or deliberate indifference. |
Key Cases Cited
- Halberstam v. Welch, 705 F.2d 472 (D.C. Cir. 1983) (intracorporate conspiracy doctrine requires scope of employment unless personal stake)
- Gladden v. Barry, 558 F. Supp. 676 (D.D.C. 1983) (intracorporate conspiracy doctrine and its limitations)
- Kivanc v. Ramsey, 407 F. Supp. 2d 270 (D.D.C. 2006) (limits of intracorporate conspiracy doctrine; routine police decisions not coverable)
- Nader v. Democratic Nat'l Committee, 567 F.3d 692 (D.C. Cir. 2009) (conspiracy elements and reliance for civil liability)
- Martin v. Malhoyt, 830 F.2d 237 (D.C. Cir. 1987) (special relationship and bystander liability in negligence context)
- Evans-Reid v. District of Columbia, 930 A.2d 937 (D.C. 2006) (municipal vicarious liability for officers acting within scope)
- Chinn v. District of Columbia, 839 A.2d 701 (D.C. 2003) (negligence and assault/battery interplay; distinct standard of care required)
- Phelan v. City of Mount Rainier, 805 A.2d 930 (D.C. 2002) (negligence standard for supervisor liability; causal link required)