Jefferson v. Government of the District of Columbia

CourtDistrict Court, District of Columbia
DecidedJune 29, 2023
DocketCivil Action No. 2022-1436
StatusPublished

This text of Jefferson v. Government of the District of Columbia (Jefferson v. Government of the District of Columbia) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jefferson v. Government of the District of Columbia, (D.D.C. 2023).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

DOMINIQUE JEFFERSON, : : Plaintiff, : : v. : Civil Action No.: 22-1436 (RC) : DISTRICT OF COLUMBIA, et al, : Re Document No.: 12 : Defendants. :

MEMORANDUM OPINION

GRANTING IN PART AND DENYING IN PART DISTRICT OF COLUMBIA’S PARTIAL MOTION TO DISMISS

I. INTRODUCTION

Plaintiff Dominique Jefferson brings claims against the District of Columbia and

Jeannette Myrick based on his time spent in D.C. Jail, including a total of five counts, and

requests money damages, declaratory relief, and injunctive relief. The District moves under Rule

(12)(b)(1) to dismiss Mr. Jefferson’s requests for declaratory and injunctive relief. The District

also moves under Rule 12(b)(6) to dismiss one count in its entirety and one theory of liability

under another count. For the reasons set forth below, the Court GRANTS in part and DENIES in

part the District’s motion to dismiss.

II. FACTUAL BACKGROUND

The Reentry and Sanctions Center (“RSC”) is a short-term residential patient facility

operated by the Court Services and Offender Supervision Agency (“CSOSA”) that houses

“defendants with mental health and substance abuse disorders” and has capacity for 102

individuals at a time. Compl. ¶¶ 8, 10, ECF No. 1. Criminal defendants held in custody may be directly released into the custody of CSOSA for a “bed-to-bed” transfer from D.C. Jail to the

RSC.1 Compl. ¶ 17. Mr. Jefferson alleges that judges “routinely and frequently” include

inpatient treatment at the RSC as a condition of probation or pre-trial release. See Compl. ¶¶ 14–

16. But capacity constraints at the RSC mean that defendants ordered to be released from jail

into RSC placement nonetheless end up spending excess time in D.C. Jail waiting for RSC space

to open. See id. ¶ 18.

On August 16, 2021, Mr. Jefferson was sentenced to serve “180 days all jail time

suspended.” 2 Compl. ¶¶ 14, 20–21. He was also sentenced to a term of probation, which

included a condition that he undergo “[i]npatient [substance abuse] treatment through a

residential treatment facility.” Id. ¶¶ 14, 23–24. The sentencing court ordered that Mr. Jefferson

was to be immediately released from the custody of the District of Columbia Department of

Corrections (“DOC”), id. ¶¶ 21–22, 25–26, “and into the custody of Representatives of CSOSA

for a bed to bed treatment program.” Id. ¶ 25. That did not happen; the DOC instead continued

to hold Mr. Jefferson. Id. ¶ 29. The DOC did not provide any notice “to the committing judge,

to Mr. Jefferson, and to his attorney” when they decided to hold Mr. Jefferson past his release

date instead of immediately transferring him into CSOSA custody. Id. ¶ 28. Mr. Jefferson was

finally released to CSOSA “approximately 30 days” after his sentencing date. Id. ¶ 29.

Mr. Jefferson alleges two other recent examples of defendants who were held in DOC

custody beyond the date when they should have been released to CSOSA, and asserts that DOC

has a policy or custom “of holding persons ordered released to a third party until the third party

1 The complaint uses “D.C. Jail” to refer to the District of Columbia’s Central Detention Facility and the Correctional Treatment Facility. 2 As required at the motion to dismiss stage, the Court recounts the allegations in the Complaint as if true. See Sparrow v. United Air Lines, Inc., 216 F.3d 1111, 1113 (D.C. Cir. 2000).

2 comes to fetch them.” Id. ¶¶ 33, 54. He adds that DOC knows that CSOSA has a “longstanding

practice” of not picking up inmates from DOC until “two or more weeks” have elapsed after the

conclusion of their sentences. Id. ¶ 64. Mr. Jefferson asserts that the DOC decides to “shift[]

blame” to CSOSA and other parties rather than taking active measures to avoid detaining

defendants beyond their release date. Id. ¶¶ 84, 89.

Finally, Mr. Jefferson argues that Ms. Jeannette Myrick, who serves as “Lead

Supervisory Legal Instruments Examiner” at DOC’s Records Office, is individually at fault for

his overdetention. Id. ¶¶ 99–101. He alleges that Ms. Myrick was responsible for ensuring DOC

had authority to detain inmates, and that she failed to guarantee his release on his release date.

Id. ¶¶ 108–09. Ms. Myrick was allegedly acting within the scope of her employment with the

District during these wrongful acts. Id. ¶ 6.

Mr. Jefferson now brings suit based on his alleged wrongful overdetention. The District

seeks partial dismissal of the Complaint under Rule 12(b)(1) and 12(b)(6), focusing on (1) Mr.

Jefferson’s request for declaratory and injunctive relief; (2) Mr. Jefferson’s respondeat superior

liability claim against the District; and (3) Mr. Jefferson’s theory of liability that the DOC has an

explicit policy of overdetention.

III. LEGAL STANDARD

A motion to dismiss under Rule 12(b)(6) does not test a plaintiff’s likelihood of success

on the merits; rather, it tests whether a plaintiff has properly stated a claim. Scheuer v. Rhodes,

416 U.S. 232, 236 (1974), abrogated on other grounds by Harlow v. Fitzgerald, 457 U.S. 800

(1982); Brewer v. District of Columbia, 891 F. Supp. 2d 126, 130 (D.D.C. 2012). When

reviewing a motion to dismiss, a court should presume that the complaint’s factual allegations

are true and construe them liberally in the plaintiff’s favor. United States v. Philip Morris, Inc.,

3 116 F. Supp. 2d 131, 135 (D.D.C. 2000). The complaint must still “contain 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)).

“Threadbare recitals of the elements of a cause of action, supported by mere conclusory

statements,” are insufficient to withstand a motion to dismiss. Id. at 678. A court need not

accept a plaintiff’s legal conclusions as true, id., nor must a court presume the veracity of legal

conclusions that are couched as factual allegations. Twombly, 550 U.S. at 555.

For a motion to dismiss under Rule 12(b)(1), the plaintiff has the burden of proving that

the Court has subject-matter jurisdiction to hear his claims. See Lujan v. Defenders of Wildlife,

504 U.S. 555, 561 (1992). A court has an “affirmative obligation to ensure that it is acting

within the scope of its jurisdictional authority.” Grand Lodge of the Fraternal Order of Police v.

Ashcroft, 185 F.Supp.2d 9, 13 (D.D.C. 2001). For this reason, “the [p]laintiff’s factual

allegations in the complaint . . . will bear closer scrutiny in resolving a 12(b)(1) motion than in

resolving a 12(b)(6) motion for failure to state a claim.” Id. at 13–14 (quotation omitted).

Additionally, under Rule 12(b)(1), the Court “may consider materials outside the pleadings in

deciding whether to grant a motion to dismiss for lack of jurisdiction.” Jerome Stevens Pharms.

v.

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Related

Scheuer v. Rhodes
416 U.S. 232 (Supreme Court, 1974)
Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Harlow v. Fitzgerald
457 U.S. 800 (Supreme Court, 1982)
City of Los Angeles v. Lyons
461 U.S. 95 (Supreme Court, 1983)
City of Oklahoma v. Tuttle
471 U.S. 808 (Supreme Court, 1985)
Lujan v. Defenders of Wildlife
504 U.S. 555 (Supreme Court, 1992)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Sparrow, Victor H. v. United Airlines Inc
216 F.3d 1111 (D.C. Circuit, 2000)
Baker v. District of Columbia
326 F.3d 1302 (D.C. Circuit, 2003)
Dearth v. Holder
641 F.3d 499 (D.C. Circuit, 2011)
Clapper v. Amnesty International USA
133 S. Ct. 1138 (Supreme Court, 2013)
Dingle v. District of Columbia
571 F. Supp. 2d 87 (District of Columbia, 2008)
Holder v. District of Columbia
700 A.2d 738 (District of Columbia Court of Appeals, 1997)

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