Brown v. Metro Transit Police Department

637 F. App'x 3 (D.C. Cir. 2016) · United States Court of Appeals for the District of Columbia Circuit · March 3, 2016

Summary

The D.C. Circuit affirmed summary judgment for the appellees in a false-arrest action arising from an arrest at a District of Columbia Metrorail station. The court held that the Metro Transit Police officer had authority to arrest the appellant and probable cause to do so, and noted that the disposition would not be published.

Court
United States Court of Appeals for the District of Columbia Circuit
Writing for the Court
Brown; Ginsburg; Tatel
Jurisdiction
Federal
Decision date
March 3, 2016
Procedural posture
Appellant appealed the District Court's order granting appellees summary judgment on his false-arrest claim.
Standard of review
Summary judgment is appropriate when the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.
Precedential value
Unpublished, nonprecedential disposition under D.C. Circuit Rule 36
Parties
Brown v. Metro Transit Police Department
Disposition
affirmed

Topics

false arrestsummary judgmentsection 1983standard of reviewappellate procedure

Practice areas

civil rightstortscivil procedureappellate procedure

Questions Presented

  1. Whether summary judgment was proper on Brown's false-arrest claim.
  2. Whether the Metro Transit Police officer had authority to arrest Brown and probable cause sufficient to defeat the false-arrest claim.

Holdings

  1. Appellees were entitled to summary judgment because the unrebutted evidence established that the Metro Transit Police officer had authority to arrest Brown and probable cause to do so.

Key quotations

the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law. (637 F. App'x at 3)

Factual background

A Metro Transit Police officer arrested Brown at a District of Columbia Metrorail station. The evidence presented by appellees, and not rebutted by Brown, established that the officer had authority to make arrests and probable cause to arrest Brown.

Procedural history

The United States District Court for the District of Columbia entered an order on April 1, 2015. On appeal, the D.C. Circuit considered the record and appellant's brief and affirmed the district court's order.

Court Document

Open PDF
Loading document…