Singletary v. District of Columbia
412 U.S. App. D.C. 351
D.C. Cir.2014Background
- Singletary’s parole was revoked in 1996 based primarily on multiple hearsay witnesses with no firsthand knowledge.
- A 2010 habeas decision found the revocation violated due process because the evidence lacked reliability.
- Singletary sued the District of Columbia under 42 U.S.C. § 1983 seeking damages for the ten years of confinement following revocation.
- The district court held the District liable under Monell theory, finding the Board’s action was the District’s final policymaking decision.
- The jury awarded Singletary $2.3 million for damages; the district court denied a new trial and the District appealed.
- The court vacated the district court’s judgment and held that the Board’s revocation could not be attributed to the District as a final policymaker.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rooker-Feldman bars the claim | Singletary’s suit does not seek to overturn a state court judgment. | Rooker-Feldman could bar claims challenging state-court outcomes. | Rooker-Feldman does not bar the § 1983 claim. |
| Whether the District is liable under Monell for the Board’s decision | Board’s revocation as final decisionmaker makes District liable. | Board’s action was not the District’s final policymaking decision in parole revocation. | District not liable; no final policymaker authority shown. |
| Whether the Board was a final policymaker authorized to create District policy | Board acts as final authority in parole revocation. | Mayor delegated rulemaking; Board lacked authority to establish parole-revocation policy. | Board not a final policymaker; District not liable under Pembaur/Praprotnik framework. |
| Whether a District policy or custom caused the violation | There existed a policy or practice of relying on unreliable evidence. | No formal policy or pervasive custom; failure to show policy-based causation. | No policy or custom shown; Monell liability rejected. |
Key Cases Cited
- Monell v. Department of Social Services, 436 U.S. 658 (1978) (municipal liability requires policy or custom causing the violation)
- Pembaur v. City of Cincinnati, 475 U.S. 469 (1986) (final policymaker doctrine for individual-actor liability)
- Praprotnik v. City of St. Louis, 485 U.S. 112 (1988) (scope of official policy and policymaker authority)
- City of Canton v. Harris, 489 U.S. 378 (1989) (supervisor liability through municipal policy; failure to train and policy)
- Brown v. District of Columbia, 514 F.3d 1279 (D.C. Cir. 2008) (implications for policy and custom in Monell claims)
- Baker v. District of Columbia, 326 F.3d 1302 (D.C. Cir. 2003) (policy/custom causation framework for municipal liability)
- Skinner v. Switzer, 131 S. Ct. 1289 (2011) (Rooker-Feldman narrow scope; parallel litigation not barred)
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (2005) (Rooker-Feldman limited to state-court judgments review)
- Verizon Md. Inc. v. Pub. Serv. Comm’n, 535 U.S. 635 (2002) (Rooker-Feldman remains narrow; overlapping proceedings allowed)