Waker v. Brown
2010 U.S. Dist. LEXIS 129959
| D.D.C. | 2010Background
- Plaintiff Joseph R. Waker, Jr., proceeding pro se, sues DC officials and officers under §1983 for alleged constitutional deprivations related to a 2009 arrest on a fugitive warrant.
- Arrest occurred April 1, 2009, in DC based on a Charles County, Maryland fugitive-from-justice warrant; plaintiff was detained at DC Jail from April 1–6, 2009.
- Maryland charges were nolle prosequi on August 25, 2009; plaintiff alleges the arrest warrant affidavit contained inaccurate information and was facially invalid.
- During detention he claims denial of a telephone call, family visits, adequate medical care, proper diet, clean clothing and basic necessities; he also describes conditions as dirty.
- Plaintiff seeks $15 million in compensatory damages from DC for negligent/contractual style claims and $15 million in damages from arresting officers and jail officials, plus injunctive relief.
- Defendants Fenty, Lanier, and Brown move to dismiss personal-capacity claims; MPD and DOC officers move for dismissal; plaintiff moves to compel officer identities.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Fenty, Lanier, and Brown are liable in their personal capacities | Fenty, Lanier and Brown supervised wrongdoers and were responsible. | Supervisory status cannot support §1983 liability absent direct participation. | Dismissed in their personal capacities. |
| Whether the official-capacity claims against DC survive | DC bears responsibility for ongoing policies causing harm. | Proper defendant is the District; service issues aside, suit should proceed against DC. | DC substituted as proper defendant for surviving official-capacity claim. |
| Whether MPD Officers Edwards and Twentymon are dismissible under 28 U.S.C. § 1915 | Officers contributed to false arrest via warrant processing. | No federal claim against them; warrant-based arrest does not violate due process as a matter of law. | Dismissed sua sponte under §1915(e)(2). |
| Whether plaintiff states a due process claim concerning the arrest warrant | Arrest based on possibly invalid warrant violated due process. | Arrest based on valid fugitive-warrant; no constitutional violation shown. | No due process violation; warrant reliance justified; no federal claim against Edwards/Twentymon. |
Key Cases Cited
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (plaintiff must plead grounds of entitlement to relief, not just labels)
- Ashcroft v. Iqbal, 129 S. Ct. 1937 (2009) (plausibility standard; supervisory liability requires direct participation)
- Kowal v. MCI Communications Corp., 16 F.3d 1271 (D.C. Cir. 1994) (grounds required beyond mere allegations)
- Cameron v. Thornburgh, 983 F.2d 253 (D.C. Cir. 1993) (supervisory liability limits on §1983 claims)
- Meyer v. Reno, 911 F. Supp. 11 (D.D.C. 1996) (personal involvement required for §1983 liability)
- Price v. Kelly, 847 F. Supp. 163 (D.D.C. 1994) (jurisdictional and procedural standards for §1983 claims)
- Smith v. Janey, 664 F. Supp. 2d 1 (D.D.C. 2009) (treats substitution of the proper defendant when government entity receives notice)
- Kentucky v. Graham, 473 U.S. 159 (1985) (test for official-capacity suits and municipal liability)
- Baker v. McCollan, 443 U.S. 137 (1979) (due process in arrest on probable cause; innocence not required for arrest validity)