District of Columbia Court of Appeals
Sharon Currie Scott, Appellant v. District of Columbia, Appellees
June 6, 1985493 A.2d 319
Summary
The court affirmed summary judgment for the District of Columbia and Officer Benton on the false-arrest and false-imprisonment claims because Benton reasonably and in good faith arrested appellant based on a facially valid warrant and matching identifying information. It also held that the amended complaint did not adequately plead an independent negligence claim against the District because it focused solely on Benton's conduct and did not provide notice of negligence in the warrant-entry process or WALES system. The court further rejected the challenge to the duration of appellant's detention because completing routine processing was not shown to involve intentional or unnecessary delay.
Holding
- False arrest, false imprisonment, and continued detention. Summary judgment was proper for Officer Benton because he had a good-faith, reasonable basis to arrest appellant when the facially valid WALES printout identified her by matching name, address, birth date, race, and sex, and appellant offered no properly supported material factual dispute. The continued detention for completion of routine processing was also not unreasonable absent evidence of intentional or unnecessary delay. Because the officer was not liable, the District likewise was not liable under respondeat superior.
- Adequacy of the negligence pleading against the District of Columbia. The complaint did not sufficiently state an independent negligence claim against the District. Although negligence was listed in the caption, the allegations addressed only false arrest, false imprisonment, and Benton's alleged conduct; they did not allege negligence by the warrant clerk or a defect in the WALES system, and therefore did not give the District adequate notice of the claim within the limitations period.
Docket 84-136
Cited authorities
- R. 56(c)
- R. 8(a)
- R. 8(f)
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