Tyson v. Dist. of Columbia

CHRISTOPHER TYSON, Plaintiff, v. DISTRICT OF COLUMBIA, et al., Defendants.

Civil Action No.: 20-1450 (RC)

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

March 8, 2021

Re Document Nos.: 12, 13, 14, 18

MEMORANDUM OPINION

GRANTING IN PART AND DENYING IN PART DEFENDANTS' MOTION TO DISMISS

I. INTRODUCTION

At the conclusion of Plaintiff Christopher Tyson's criminal sentence of incarceration, Judge Marisa Demeo of the D.C. Superior Court ordered that he receive a bed-to-bed transfer to the Reentry and Sanctions Center ("RSC") for inpatient treatment. Under Judge Demeo's order, when the term of incarceration expired, the Court Services and Offender Supervision Agency ("CSOSA") would take over custody of Plaintiff from the D.C. Jail and place him in the rehabilitation center. Plaintiff's term of incarceration expired on April 29, 2019. He was not released from the D.C. Jail's custody and transferred to RSC until May 23, 2019. Through this civil action, Plaintiff brings common law tort and constitutional claims against the Defendants for this alleged overdetention. The District of Columbia, Lennard Johnson (the Warden of the D.C. Jail), and Jeanette Myrick (Lead Supervisory Legal Instruments Examiner in the Record Office) (together "Defendants") have moved to dismiss Plaintiff's Amended Complaint. For the reasons stated below, the Court will grant the motion to dismiss Plaintiff's claims brought under 42 U.S.C. § 1983 for failure to state a claim, will grant the motion with respect to the common law tort claims against Defendant Johnson, and will deny the motion with respect to the claims against Defendant Myrick.

II. BACKGROUND

As alleged in the Amended Complaint, Plaintiff was sentenced by Judge Demeo to serve six months of incarceration on March 22, 2019. Am. Compl. ¶ 12, ECF No. 16. Judge Demeo's order, directed to the superintendent of the D.C. Jail, stated the following: "It is HEREBY ORDERED that the defendant be released from your custody at the conclusion of the Sentence of Incarceration and into the custody of Representatives of CSOSA for a Bed-to-Bed Transfer to the Reentry and Sanctions Center (RSC)." Id. ¶ 16; see also Defs.' Mot. Dismiss Ex. C, ECF No. 18-4 (emphasis in original). Because Plaintiff had been incarcerated at the D.C. Jail since October 30, 2018, he was to be released into the custody of CSOSA on April 29, 2019 under the terms of Judge Demeo's order. Am. Compl. ¶ 13.

On April 24, 2019, the District of Columbia Department of Corrections ("DOC") let CSOSA know that Plaintiff would be available on April 30, 2019 to be transferred to RSC. Id. ¶ 17. On April 26, DOC emailed CSOSA a second time to schedule his pickup on April 30. Id. ¶ 18. On May 1, DOC again contacted CSOSA to advise that Plaintiff's sentence had expired and that he was available for pickup and transfer to RSC. Id. ¶ 19. CSOSA did not respond. Id. After another five days, CSOSA responded and scheduled Plaintiff's pickup for May 15. Id. ¶ 21. Two days later, CSOSA rescheduled Plaintiff's pick up for May 23. Id. ¶ 22. Plaintiff remained in the custody of DOC at the D.C. Jail until May 23, when he was finally picked up and transferred to RSC, twenty-four days after the expiration of his sentence of incarceration. Id. ¶¶ 24, 27.

In his Amended Complaint, Plaintiff brings four counts against Defendants arising out of his overdetention. See id. ¶¶ 39-88. First, Plaintiff brings a count of false imprisonment against Defendants Johnson and Myrick. Id. ¶¶ 39-49. He alleges that Defendants Johnson and Myrick, in their individual capacities, imprisoned him without justification beyond his release date. See id. Second, Plaintiff brings a count of negligence against Defendants Johnson and Myrick for allegedly breaching their duty to release Plaintiff on his release date. See id. ¶¶ 50-63. Plaintiff's third and fourth counts are brought under 42 U.S.C. § 1983 against the District of Columbia (the "District"). See id. ¶¶ 64-88. Plaintiff alleges that DOC has a policy, custom, or practice of holding inmates to be transferred to a third party beyond their release dates if the third party fails to schedule a pickup. Id. ¶¶ 31-32. He claims that this policy, custom, or practice resulted in violations of his substantive and procedural due process rights. See id. Defendants have moved to dismiss each claim raised in the Amended Complaint,¹ arguing that Plaintiff has failed to allege sufficient facts to state a plausible claim to relief. See Defs.' Mot. Dismiss ("Defs.' Mot."), ECF No. 18. Defendants' motion is ripe for decision. See Pl.'s Opp'n, ECF No. 20; Defs.' Reply, ECF No. 21.

III. LEGAL STANDARD

The Federal Rules of Civil Procedure require that a complaint contain "a short and plain statement of the claim" in order to give the defendant fair notice of the claim and the grounds upon which it rests. Fed. R. Civ. P. 8(a)(2); see also Erickson v. Pardus, 551 U.S. 89, 93 (2007)(per curiam). A motion to dismiss under Rule 12(b)(6) does not test a plaintiff's ultimate likelihood of success on the merits; rather, it tests whether a plaintiff has properly stated a claim. See Scheuer v. Rhodes, 416 U.S. 232, 236 (1974). The complaint's factual allegations are to be taken as true, and the court is to construe them liberally in the plaintiff's favor. See, e.g., United States v. Philip Morris, Inc., 116 F. Supp. 2d 131, 135 (D.D.C. 2000). Notwithstanding this liberal construal, the court deciding a Rule 12 motion must parse the complaint for "sufficient factual matter, accepted as true, to 'state a claim to relief that is plausible on its face.'" Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). This plausibility requirement means that a plaintiff's factual allegations "must be enough to raise a right to relief above the speculative level, on the assumption that all the allegations in the complaint are true (even if doubtful in fact)." Twombly, 550 U.S. at 555-56 (citations omitted). "Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements," are insufficient to withstand a motion to dismiss. Iqbal, 556 U.S. at 678. A court need not accept a plaintiff's legal conclusions as true, see id., nor must a court presume the veracity of legal conclusions that are couched as factual allegations, see Twombly, 550 U.S. at 555.

IV. ANALYSIS

As noted above, Plaintiff brings claims of false imprisonment and negligence against Defendants Johnson and Myrick and claims under 42 U.S.C. § 1983 against the District. The Court addresses the claims in the order they appear in the Amended Complaint.

A. False Imprisonment

The common law tort of false imprisonment requires the establishment of two essential elements: "(1) the detention or restraint of one against his will, within boundaries fixed by thedefendants, and (2) the unlawfulness of the restraint." Jones v. District of Columbia, No. 16-cv-2405, 2019 WL 5690341, at *6 (D.D.C. June 13, 2019) (quoting Faniel v. Chesapeake & Potomac Tel. Co., 404 A.2d 147, 150 (D.C. 1979)). "A detention is presumed to be unlawful once a plaintiff alleges that he was imprisoned without process." Smith v. District of Columbia, 306 F. Supp. 3d 223, 260 (D.D.C. 2018) (citing Clarke v. District of Columbia, 311 A.2d 508, 511 (D.C. 1973)). At that point, "[t]he burden then shifts to the defendant to justify the restraint as lawful," which constitutes "an element of a defense to be raised and proved by the defendant." Id.

Plaintiff alleges sufficient facts to state a plausible claim of false imprisonment against Defendant Myrick. The Amended Complaint includes allegations that Defendant Myrick has the responsibility "to ensure that all inmates at the D.C. Jail are detained with sufficient authorizing documentation" and to process the release of inmates. Am. Compl. ¶ 10; see also id. ¶ 46 ("[Defendant Myrick] had responsibility for checking the sentence calculation and other processes by which [Plaintiff] should have been released on his Release Date."). Plaintiff alleges that Defendant Myrick "received the May 6, 2019 and May 8, 2019 emails from CSOSA stating that it would pick up [Plaintiff] May 15 and May 23, respectively." Id. ¶ 46. This allegation plausibly suggests that Defendant Myrick personally knew about Plaintiff's situation.² Plaintiff alleges that the imprisonment beyond his date of release from incarceration was unlawful because Judge Demeo's order required DOC to release him at the conclusion of his sentence of incarceration into the custody of CSOSA. See id. ¶¶ 16, 27, 47-48. In their motion, Defendants argue, without citation to any controlling or persuasive precedent, that Plaintiff's twenty-four-day overdetention was not unlawful because Judge Demeo's order required DOC to release Plaintiff to the custody of CSOSA and CSOSA failed to schedule his pickup until May 23. Defs.' Mot. at 17. Although Judge Demeo's order called for a bed-to-bed transfer facilitated by CSOSA and CSOSA did not schedule the pickup until May 23, it does not necessarily follow that continued detention beyond the release date—without any additional process—is legal. Defendants offer no support for their position that continuing incarceration should be legally sanctioned, potentially indefinitely, in a situation such as Plaintiff's. Moreover, arguments speaking to the legality of Plaintiff's incarceration beyond his release date relate to a possible affirmative defense, not to whether Plaintiff has pled sufficient facts to survive a motion to dismiss. See Smith, 306 F. Supp. 3d at 260. Because the Amended Complaint alleges facts speaking to the required elements as to Defendant Myrick, the Court finds Plaintiff has stated a claim that survives Defendants' motion to dismiss.

Plaintiff has failed to allege sufficient facts to state a claim of false imprisonment against Defendant Johnson. In contrast to the allegations against Defendant Myrick, the Amended...