Williams v. District of Columbia
268 F. Supp. 3d 178
| D.D.C. | 2017Background
- On Feb. 22, 2014 Ray B. Williams engaged in an altercation at DC Metro Wine & Spirits; store employees ejected him, he returned repeatedly, and officers Merritt and Bines were summoned.
- Merritt arrived first, spoke to store employees who identified Williams as the assailant; Merritt directed Bines to arrest Williams.
- A physical struggle ensued while officers attempted to handcuff Williams; video shows Williams and officers falling to the floor, Bines delivering several strikes, then pinning Williams.
- While pinned, Bines delivered four additional blows to Williams’ upper body/head before officers gained control of his hands and handcuffed him. Williams suffered a broken nose, head contusion, and subgaleal hematoma.
- Williams sued under § 1983 (Fourth Amendment excessive force and unlawful arrest) and D.C. common law (assault & battery, false arrest, intentional infliction of emotional distress). Several claims were previously dismissed; remaining claims proceeded to summary judgment.
- The court denied summary judgment as to Bines and the District for excessive force, assault & battery, and intentional infliction of emotional distress; granted summary judgment for Merritt and on the unlawful-arrest/Fourth Amendment claim (qualified immunity) and other dismissed claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether arrest without warrant violated Fourth Amendment (probable cause) | Williams: officers lacked probable cause and should have interviewed him before arrest | Defendants: employees identified Williams as assailant; officers had probable cause and qualified immunity | Court: Officers had probable cause from eyewitness ID; arrest did not violate Fourth Amendment; qualified immunity for arrest claim granted |
| Whether arrest violated D.C. warrantless-arrest statute (D.C. Code §23-581) | Williams: statute requires more than probable cause (i.e., additional criteria not present) | Defendants: officers reasonably believed Williams posed an immediate threat to patrons/employees so warrantless arrest authorized | Court: arrest justified under statute because officers could reasonably believe Williams posed a continuing threat to store employees after returning; false arrest claim denied |
| Whether Bines used excessive force in violation of Fourth Amendment (qualified immunity) | Williams: after being pinned/subdued he was repeatedly struck in head — force was excessive and unreasonable | Defendants: strikes were necessary to subdue and handcuff Williams; he had resisted | Court: material fact exists whether Williams was subdued when struck; a reasonable jury could find Bines used excessive force; right clearly established; summary judgment denied as to Bines (qualified immunity denied) |
| Whether officers’ conduct supports assault & battery and intentional infliction of emotional distress (IIED) under D.C. law | Williams: strikes after subdual were extreme/outrageous causing severe emotional distress | Defendants: qualified privilege to use reasonable force; conduct not extreme; no severe emotional distress evidence | Court: Bines’ conduct could be objectively unreasonable and sufficiently outrageous; IIED and assault & battery claims survive vs. Bines and District; Merritt entitled to judgment on these claims |
Key Cases Cited
- Fenwick v. Pudimott, 778 F.3d 133 (D.C. Cir.) (qualified immunity framework explained)
- Saucier v. Katz, 533 U.S. 194 (U.S.) (qualified immunity two-prong test)
- Plumhoff v. Rickard, 134 S. Ct. 2012 (U.S.) (qualified immunity discretion on analysis order)
- Davenpeck v. Alford, 543 U.S. 146 (U.S.) (probable cause suffices for warrantless arrest)
- Beck v. Ohio, 379 U.S. 89 (U.S.) (definition of probable cause)
- Johnson v. District of Columbia, 528 F.3d 969 (D.C. Cir.) (force after suspect subdued is unreasonable)
- Mazloum v. District of Columbia Metropolitan Police Dep't, 576 F. Supp. 2d 25 (D.D.C.) (repeatedly smashing a subdued suspect's head into ground is excessive)
- Harris v. Department of Veterans Affairs, 776 F.3d 907 (D.C. Cir.) (police beating after subdual can support IIED claim)