Xingru Lin v. District of Columbia
268 F. Supp. 3d 91
| D.D.C. | 2017Background
- Plaintiff, a Chinese-speaking night-shift bus ticket agent in D.C., alleges four adverse encounters with MPD between Dec 2015 and Apr 2016, including two arrests (Feb 15 and Apr 12, 2016).
- Feb 15 encounter: plaintiff alleges excessive force (pushed, pinned, stepped on, arms twisted), handcuffed, briefly released after review of video, then re-arrested after attempting to record badge numbers; detained ~19 hours and taken to hospital where she was examined in presence of male officers.
- Apr 12 encounter: plaintiff alleges handcuffing and arrest without warrant, inadequate interpretation, refusal to review CCTV, short detention (~2 hours) and citation to appear in court.
- Plaintiff pleaded multiple tort and constitutional claims (42 U.S.C. § 1983 municipal claim, IIED, negligence, malicious prosecution, negligent supervision/training) and alleged municipal policy/custom or failure to train/supervise.
- Procedural posture: District moved to dismiss or partial summary judgment; court considered Rule 12(b)(6) standards and denied to the extent detailed below.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| §1983 municipal liability (Monell) | District policy/custom or failure to train caused officers’ conduct | No facts allege a policy, custom, or deliberate choice to under-train; only isolated officer misconduct | Dismissed — §1983 claim against D.C. failed for lack of municipal policy/custom allegations |
| Negligence (public duty doctrine) | Multiple contacts with MPD created special relationship / reliance | Public duty doctrine bars suit absent special relationship | Dismissed — no special relationship or justifiable reliance shown |
| Malicious prosecution | Arrests and subsequent dismissal support claim | No favorable termination on the merits alleged | Dismissed — plaintiff did not plead a termination favorable on the merits |
| Intentional infliction of emotional distress (IIED) | Extreme police conduct, fabrication of charges, humiliating hospital exam caused severe distress | Conduct not sufficiently outrageous as matter of law | Not dismissed — IIED survives pleading stage given allegations of excessive force, fabrication of arrest, humilia‑tion and overnight detention |
| Negligent supervision/training (D.C. Code §12‑309) | Notices filed under §12‑309 described officer misconduct and training issues | Notices insufficient to put D.C. on notice of negligent-training claim | Not dismissed — court finds §12‑309 notices adequate to apprise D.C. of claim |
Key Cases Cited
- Monell v. Department of Social Services, 436 U.S. 658 (U.S. 1978) (municipal liability under §1983 requires an unconstitutional policy or custom)
- Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (pleading standards require factual allegations supporting plausible claim)
- Bell Atlantic v. Twombly, 550 U.S. 544 (U.S. 2007) (plausibility pleading standard)
- City of Canton v. Harris, 489 U.S. 378 (U.S. 1989) (failure-to-train municipal liability requires deliberate indifference/municipal policy)
- Hines v. District of Columbia, 580 A.2d 133 (D.C. 1990) (public duty doctrine: government owes duties to public generally, not individuals absent special relationship)
- DeWitt v. District of Columbia, 43 A.3d 291 (D.C. 2012) (elements of malicious prosecution in D.C.)
- Chen v. District of Columbia, 256 F.R.D. 267 (D.D.C. 2009) (IIED pleadings survived where plaintiff alleged detention, force, denial of interpreter, humiliating search)