Wood v. Government of the District of Columbia
Civil Action No. 2014-2066
D.D.C.May 31, 2017Background
- On Oct. 27, 2013, MPD officers responded to a nearby robbery/assault; officers proceeded toward a house at 1214 Jamaica St. where David Wood lived. A witness’s identification of the house is disputed.
- Wood, wearing only underwear and a T‑shirt, exited his home panicked after seeing flashing red light; officers told him to stop and one officer grabbed and handcuffed an arm.
- A physical altercation followed: officers tackled Wood, multiple officers and Wood exchanged blows, and Wood alleges officers continued to kick/punch/step on him after he was handcuffed.
- Wood was arrested for assault on a police officer (APO), tried in D.C. Superior Court, and acquitted. He then sued under § 1983 (false arrest, malicious prosecution, excessive force, false evidence) and common‑law torts (assault, false arrest, malicious prosecution).
- Court grants summary judgment for defendants on false arrest and malicious prosecution claims (probable cause existed for APO). Court denies summary judgment on excessive‑force and common‑law assault claims to the extent force allegedly continued after Wood was subdued and handcuffed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Legality of initial stop / investigatory seizure | Wood: officers lacked reasonable, articulable suspicion to stop him | Defs: circumstances (violent crime nearby, time of night, Wood’s panicked appearance, proximity) gave reasonable suspicion | Court: reasonable suspicion existed to justify investigatory stop |
| Probable cause for arrest (APO) | Wood: no probable cause because witness ID/location disputed and his resistance was minimal | Defs: Wood resisted, gestured, refused commands, and exchanged blows — reasonable/probable cause for APO; alternatively qualified immunity | Court: officers had probable cause for APO (or reasonable belief thereof); false arrest and § 1983 malicious prosecution claims dismissed |
| Excessive force during takedown and melee | Wood: officers used excessive force (punches, kicks, stepping on him), including after he was subdued | Defs: force was reasonable to effectuate stop/arrest; any force ceased after handcuffing | Court: force during stop/takedown/struggle not clearly excessive; but disputed material fact exists whether officers used gratuitous force after Wood was fully handcuffed—summary judgment denied on that claim |
| Common‑law assault / malicious prosecution / false arrest under D.C. law | Wood: common‑law claims independent from § 1983 | Defs: probable cause negates both constitutional and common‑law false arrest and malicious prosecution claims; assault governed by same reasonableness standard as § 1983 excessive force | Court: common‑law false arrest and malicious prosecution dismissed (probable cause); assault claim survives to extent it parallels alleged post‑handcuff excessive force |
Key Cases Cited
- Graham v. Connor, 490 U.S. 386 (use‑of‑force claims judged by Fourth Amendment objective‑reasonableness standard)
- Tolan v. Cotton, 134 S. Ct. 1861 (summary judgment on qualified immunity cannot resolve genuine factual disputes; view facts in plaintiff’s favor)
- Hunter v. Bryant, 502 U.S. 224 (officers reasonably but mistakenly believing probable cause exists are entitled to immunity)
- Pitt v. District of Columbia, 491 F.3d 494 (malicious prosecution actionable under § 1983 only where seizure occurred without probable cause)
- Johnson v. District of Columbia, 528 F.3d 969 (excessive force precedents; force against submissive/prone arrestee can be excessive)