Quander v. District of Columbia

CourtDistrict Court, District of Columbia
DecidedSeptember 29, 2023
DocketCivil Action No. 2022-2539
StatusPublished

This text of Quander v. District of Columbia (Quander v. 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
Quander v. District of Columbia, (D.D.C. 2023).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

DOUGLAS QUANDER,

Plaintiff,

v. Civil Action No. 22-cv-2539 (CJN)

DISTRICT OF COLUMBIA, et al.,

Defendant.

ORDER

For the reasons stated in the accompanying Memorandum Opinion, ECF No. 18, it is

ORDERED that the Defendant’s Motion, ECF No. 5, is GRANTED; it is further

ORDERED that the Defendant’s Motion, ECF No. 10, is GRANTED; it is further

ORDERED that Plaintiff’s complaint is dismissed.

The Clerk of Court is directed to terminate this case.

This is a final, appealable order.

DATE: September 29, 2023 CARL J. NICHOLS United States District Judge

1 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

MEMORANDUM OPINION

Plaintiff Douglas Quander alleges that, while he was detained at the District of Columbia

jail, Defendants violated his Fourth, Eighth, and Fourteenth Amendment rights when they failed

to handcuff him prior to restraining him for disorderly conduct. See ECF No. 1at 3. He seeks

relief under 42 U.S.C. § 1983. Defendants move to dismiss on various grounds. See ECF Nos. 5,

10. For the reasons detailed below, the Court agrees and grants Defendants’ motions.

BACKGROUND

Quander was a pretrial detainee charged with various drug crimes in the Southern District

of Maryland and ordered detained pending trial. See Judgment, United States v. Quander, No. 18-

cr-334-GJH-1 (S.D. Md. Mar. 23, 2021), ECF No. 111. For reasons that his complaint does not

make clear, Quander was administratively segregated from other inmates at some point during his

pretrial detention. According to the complaint, on August 24, 2019, certain unknown corrections

officers, led by Defendant Andre Taylor, became aware that Quander “was smoking in the cell.”

ECF No. 1, at 2. Quander alleges that the officers pepper sprayed into his cell before entering it.

Id at 2-3. Quander apparently acknowledges that he “swung on four officers,” as a result of which

1 he was restrained with “his head being smashed … into a toilet.” Id at 3. He allegedly suffered

substantial injuries from this restraint and other acts.

Plaintiff alleges that the District of Columbia, Corporal Andre Taylor, those unknown

officers, and Thomas Faust (Director of the District of Columbia Department of Corrections)

violated his constitutional rights, primarily by failing to handcuff him before entering his cell (an

alleged policy and practice of the Jail that he claims is unconstitutional). ECF No. 1, at 5.

Defendants move to dismiss under Rule 12(b)(6) on various grounds. See ECF No. 5, 10.

LEGAL STANDARDS

When considering a motion to dismiss under Rule 12(b)(6), courts must assess whether a

complaint sufficiently alleges facts, accepted as true, to state a plausible claim for relief. See Bell

Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). A claim is plausible when it “allows the court

to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft

v. Iqbal, 556 U.S. 662, 678 (2009). A complaint that merely asserts “labels and conclusions” or

“a formulaic recitation of the elements of a cause of action will not do.” Twombly, 550 U.S. at

555.

Federal law supplies a private right of action for violations of constitutional or statutory

rights by persons acting under color of law. See 42 U.S.C. § 1983. To state a claim under section

1983, a plaintiff must sufficiently plead that he was (1) deprived of a federally secured right by (2)

persons acting under color of state law. See West v. Atkins, 487 U.S. 42, 48 (1988). In the context

of civil suits against a prison or jail, inmates must satisfy additional conditions before filing a

section 1983 action. First, federal law requires inmates to exhaust all administrative remedies.

See Prison Litigation Reform Act, 42 U.S.C. § 1997e(a); see also Porter v. Nussle, 534 U.S. 516,

532 (2002) (“The PLRA's exhaustion requirement applies to all inmate suits about prison life,

2 whether they involve general circumstances or particular episodes.”). Plaintiff asserts, and

defendants do not refute, that he has administratively exhausted his claims with the D.C.

Department of Corrections. See ECF No. 1, at 4.

Second, prisons and related government officials can put forward qualified immunity as an

affirmative defense. See Pearson v. Callahan, 555 U.S. 223, 231-32 (2009). Courts may consider

qualified immunity at the pleading stage because it is “an immunity from suit rather than a mere

defense to liability.” Id quoting Mitchell v. Forsyth, 472 U.S. 511, 526 (1985). A defendant is

entitled to qualified immunity if (1) the facts alleged by plaintiff do not demonstrate the violation

of a constitutional right or (2) the alleged constitutional right violated was not clearly established

at the time of the defendant’s alleged violation. See Wilson v. Layne, 526 U.S. 603, 609 (1999).

ANALYSIS

Starting with his Eighth Amendment claims, Quander was a pretrial detainee at the time of

the events here. The Eighth Amendment’s prohibition against cruel and unusual punishment,

however, only applies to inmates found guilty in a court of law. See Bell v. Wolfish, 441 U.S. 520,

535 n.16 (1979) (“The Court of Appeals properly relied on the Due Process Clause rather than the

Eighth Amendment in considering the claims of pretrial detainees.”); see also Brogsdale v. Barry,

926 F.2d 1184, 1187 (D.C. Cir. 1991). As for Quander’s Fourteenth Amendment claims, that

Amendment does not apply to the federal government or the District of Columbia. Bolling v.

Sharpe, 347 U.S. 497, 499 (1954).1 As to each Defendant, therefore, Quander has failed to state

either Eighth or Fourteenth Amendment claims.

1 The Fifth Amendment does apply to the District, but Quander’s complaint does not include a Fifth Amendment claim.

3 As for Quander’s Fourth Amendment claim, its gravamen is that he was unlawfully seized

when officers used “excessive force” against him. See ECF No. 1, at 3. The Fourth Amendment

does apply to these Defendants and prohibits them from committing unreasonable searches and

seizures. In the context of a prison, the reasonableness of a seizure is determined by “the scope of

the particular intrusion, the manner in which it is conducted, the justification for initiating it, and

the place in which it is conducted,” Wolfish, 441 U.S. at 559, keeping in mind that a “detention

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Related

Bolling v. Sharpe
347 U.S. 497 (Supreme Court, 1954)
Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Bell v. Wolfish
441 U.S. 520 (Supreme Court, 1979)
Mitchell v. Forsyth
472 U.S. 511 (Supreme Court, 1985)
Kentucky v. Graham
473 U.S. 159 (Supreme Court, 1985)
West v. Atkins
487 U.S. 42 (Supreme Court, 1988)
Wilson v. Layne
526 U.S. 603 (Supreme Court, 1999)
Porter v. Nussle
534 U.S. 516 (Supreme Court, 2002)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Pearson v. Callahan
555 U.S. 223 (Supreme Court, 2009)
Warren v. District of Columbia
353 F.3d 36 (D.C. Circuit, 2004)
Roger Rudder v. Shannon Williams
666 F.3d 790 (D.C. Circuit, 2012)

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