Winston v. District of Columbia
Civil Action No. 2023-3832
D.D.C.Mar 11, 2025Background
- Johnathan Winston was a pretrial detainee at the District of Columbia Central Detention Facility (CDF) from November 2019 to December 2022.
- Winston claimed he suffered cold cell temperatures, unsanitary and inedible food, inadequate medical care, deprivation of personal property, and was subjected to solitary confinement and retaliation.
- He was ultimately acquitted of the charges that led to his detention.
- Winston sued the District of Columbia and Deputy Warden Landerkin (official capacity) alleging violations of his constitutional rights (First, Fourth, Fifth, Sixth, Eighth Amendments) and common-law torts.
- The District removed the action to federal court and moved to dismiss; the court converted part of the motion to one for summary judgment regarding the tort claims.
- The court ultimately dismissed Winston’s constitutional claims and granted summary judgment for the District on the tort claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Municipal liability under § 1983 | Jail conditions reflected CDF policy/custom | No facts show policy/custom | No municipal liability; claims dismissed |
| Eighth Amendment claim | Jail treatment violated Eighth Amendment | Eighth Amendment inapplicable | Pretrial detainees not protected by Eighth Amendment |
| Fourth Amendment claim | Seizure of property was unlawful | Fourth Amendment inapplicable | Inmates have no expectation of privacy/protection |
| Fifth Amendment claim | Conditions amounted to punitive deprivation | Conditions not severe/deliberate | No constitutional deprivation shown |
| Sixth Amendment claim | Jail actions hindered access to courts/counsel | No facts showing access interference | Plaintiff failed to allege any actual interference |
| First Amendment retaliation | Retaliation for complaints/grievances | No specific protected activity alleged | No plausible claim; insufficient factual allegations |
| State-law tort claims (timely notice) | Harm was ongoing, asks for leniency | Notice untimely, statute strict | Notice untimely; summary judgment for District |
Key Cases Cited
- Monell v. Department of Social Services, 436 U.S. 658 (municipalities only liable under § 1983 for constitutional violations caused by their official policy/custom)
- Ashcroft v. Iqbal, 556 U.S. 662 (standard for plausibility in pleadings)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (requirement for factual specificity in complaints)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment standard)
- Hudson v. Palmer, 468 U.S. 517 (no Fourth Amendment protection against searches/seizures in prison)
- Farmer v. Brennan, 511 U.S. 825 (deliberate indifference standard for constitutional claims about prison conditions)