Rogers v. District of Columbia
880 F. Supp. 2d 163
D.D.C.2012Background
- Rogers was committed to the D.C. Jail on December 15, 2007 for multiple charges including two Bail Reform Act felonies and a possession-with-intent-to-distribute charge, and was not released until August 14, 2008.
- Rogers contends he was overdetained by about two months in 2008 due to miscalculation of jail credits.
- Defendant argues Rogers was not overdetained and that the negligent supervision claim was not properly pleaded under D.C. Code §12-309.
- Court records show sentencing in February and April 2008 with credits for time served, and docket notes indicating time-for-time credits on the April 25, 2008 sentences.
- Barnes v. District of Columbia is an ongoing class action concerning overdetention, and Rogers’ claim is stayed pending resolution of that proceeding.
- The court grants in part and denies in part the motion for summary judgment: overdetention claim remains live and is stayed pending Barnes, while the negligent training/supervision claim is dismissed as barred by §12-309.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Rogers overdetained due to miscalculated jail credits? | Rogers claims miscalculated credits extended his detention. | DC Jail properly calculated credits; no overdetention. | Issue of material fact; summary judgment denied on overdetention. |
| Is Rogers' negligent training/supervision claim barred by DC Code §12-309 notice requirements? | Notice to Judge Boasberg suffices under §12-309. | Notice to Mayor required; letter to judge does not satisfy statute. | Claim dismissed as barred by §12-309. |
Key Cases Cited
- District of Columbia v. Dunmore, 662 A.2d 1356 (D.C. 1995) (mandatory notice prerequisite to suit against D.C.)
- Barnes v. District of Columbia, 793 F. Supp. 2d 260 (D.D.C. 2011) (overdetention class action; affects damages in this case; stay pending)
- Thompson v. Linda & A., Inc., 779 F. Supp. 2d 139 (D.D.C. 2011) (judicial notice of public records allowed)
- Mangiafico v. Blumenthal, 471 F.3d 391 (2d Cir. 2000) (court may take judicial notice of docket sheets as public records)
- Doe v. Dep’t of the Treasury, 706 F. Supp. 2d 1 (D.D.C. 2009) (evidence standards for opposing summary judgment)
- Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (initial burden on movant to show absence of a genuine issue)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (threshold for genuine issues of material fact; summary judgment standard)