Reiver v. District of Columbia
925 F. Supp. 2d 1
D.D.C.2013Background
- Plaintiff Reiver was stopped on Oct. 15, 2009 in DC for driving without headlights and was arrested for DUI/OWI after field sobriety tests.
- Officer Griffin performed the stop and field sobriety tests; trial court later addresses probable cause and qualified immunity.
- Officer Edwards transported and processed the arrest; Lieutenant Hedgecock was the Watch Commander who declined to release him.
- Breathalyzer at 1:00 a.m. returned a .00, but urine testing followed and plaintiff remained detained.
- Detention journal entry was not used to release him; plaintiff was released at 9:00 a.m. after processing.
- The remaining §1983 claims allege false arrest/false imprisonment; defendants move for summary judgment on qualified immunity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether initial arrest had probable cause under qualified immunity. | Reiver argues lack of probable cause. | Griffin/Edwards contend probable cause existed. | Griffin/Edwards/collective knowledge had probable cause; qualified immunity applied. |
| Whether Edwards/Gr Hedgecock retain qualified immunity for continued detention after .00 breath test. | Detention after .00 was unlawful. | Continued detention reasonable given prior facts; not clearly unlawful. | Edwards/Hedgecock protected by qualified immunity for continued detention. |
| Whether administration/interpretation of field sobriety tests defeated probable cause. | Tests were administered improperly to undermine probable cause. | Administration acceptable; expert testimony not needed for probable cause. | No genuine dispute; administration supported probable cause; qualified immunity stands. |
| Whether Edwards could rely on collective knowledge for probable cause. | Edwards lacked firsthand knowledge. | Collective knowledge suffices for probable cause to arrest. | Edwards protected by qualified immunity under collective knowledge doctrine. |
Key Cases Cited
- Harlow v. Fitzgerald, 457 U.S. 800 (U.S. 1982) (qualified immunity framework and early determination matters)
- Pearson v. Callahan, 555 U.S. 223 (U.S. 2009) (district court may address either prong first; objective reasonableness standard)
- Malley v. Briggs, 475 U.S. 335 (U.S. 1986) (excessive focus on probable cause; standard for qualified immunity)
- Rogala v. District of Columbia, 161 F.3d 44 (D.C. Cir. 1998) (field sobriety testing authority without probable cause)
- Karamychev v. District of Columbia, 772 A.2d 806 (D.C. 2001) (nystagmus test/interpreting impairment by visual cues)
- Anand v. District of Columbia, 801 A.2d 951 (D.C. 2002) (drinking not required for DUI proof; impairment indicators)
- Poulnot v. District of Columbia, 608 A.2d 134 (D.C. 1992) (driving under the influence definition and impairment)
- Stevenson v. District of Columbia, 562 A.2d 622 (D.C. 1989) (impairment need not be shown by manner of operation)
- Whren v. United States, 517 U.S. 806 (U.S. 1996) (probable cause standard for traffic stops)