Rice v. District of Columbia
2011 U.S. Dist. LEXIS 18010
D.D.C.2011Background
- Undercover officers observed a suspected hand-to-hand narcotics transaction at 5857 Fields Place NE and relayed details to the arrest team including Officers Starliper and Stathers.
- Starliper entered 5857 Fields Place and identified a suspect; Stathers followed with his gun drawn into the back room where Rice was located.
- Stathers instructed Rice to freeze; Rice attempted to flee through a back-window while Stathers grabbed his leg and a gunshot occurred during the struggle.
- Rice was arrested and later charged in a juvenile complaint? No, a DC charge for resisting and assaulting a police officer; the charge was dismissed by the prosecutor on January 21, 2009.
- Rice filed a federal suit alleging false arrest and Fourth Amendment violations against the District and the officers; defendants moved for summary judgment on false arrest claims.
- The court analyzes whether the stop was supported by reasonable suspicion and whether there was probable cause to arrest, applying the collective knowledge doctrine.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rice's false arrest claims survive summary judgment | Rice contends no probable cause or reasonable suspicion existed. | Stathers and Starliper had reasonable suspicion and probable cause based on undercover info and Rice's flight. | Probable cause and reasonable suspicion existed; claims fail. |
Key Cases Cited
- Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (establishes Terry stop framework)
- United States v. Bailey, 622 F.3d 1 (D.C. Cir. 2010) (reasonable suspicion governs Terry stops)
- United States v. Jones, 584 F.3d 1083 (D.C. Cir. 2009) (ties stop justification to reasonable suspicion and evolving facts)
- Ornelas v. United States, 517 U.S. 690 (U.S. 1996) (probable cause and reasonable suspicion evaluated under totality of circumstances)
- Illinois v. Gates, 462 U.S. 213 (U.S. 1983) (probable cause assessment based on totality of evidence)
- Catlett, 97 F.3d 565 (D.C. Cir. 1996) (collective knowledge doctrine for probable cause)
- Devenpeck v. Alford, 543 U.S. 146 (U.S. 2004) (probable cause to arrest based on crime actually charged)
- Beck v. Ohio, 379 U.S. 89 (U.S. 1964) (probable cause standard for arrest)
- Dellums v. Powell, 566 F.2d 167 (D.C. Cir. 1977) (justify arrest through probable cause or reasonable grounds)
- Gilliam, 167 F.3d 628 (D.C. Cir. 1999) (probable cause interpretation; collective knowledge context)
- Hawkins, 595 F.2d 751 (D.C. Cir. 1978) (collective knowledge and slow-moving investigations)