Anthony Marsh II v. District of Columbia, et al.

Summary

The United States District Court for the District of Columbia considers Defendants’ partial motion to dismiss Anthony Marsh’s amended complaint arising from a 2021 investigatory stop and pat-down by MPD officers. The court dismisses Marsh’s Monell claims against the District of Columbia because the complaint does not plausibly allege a municipal policy, custom, or deliberate indifference in training, supervision, or discipline. The court also addresses claims under the D.C. Human Rights Act and treats the declaratory judgment request as a form of relief rather than a separate cause of action.

Holdings

1. The complaint did not plausibly allege that Marsh's stop resulted from a widespread, persistent municipal practice attributable to the District and therefore failed to state a Monell claim based on custom or policy.
2. The complaint did not plausibly allege deliberate indifference or a constitutionally deficient failure to train, supervise, or discipline.
3. The alleged discriminatory stop and frisk did not fall within the DCHRA provision governing District government services, facilities, programs, or benefits, so the DCHRA claim failed as a matter of law.
4. A request for declaratory relief under 28 U.S.C. § 2201 is a form of relief rather than an independent cause of action and was not treated as a separate claim.

Questions Presented

1. Whether the amended complaint plausibly alleged that a District of Columbia policy or custom caused the alleged Fourth Amendment violation for purposes of Monell municipal liability under 42 U.S.C. § 1983.
2. Whether the amended complaint plausibly alleged deliberate indifference based on the District's failure to train, supervise, or discipline MPD officers.
3. Whether the alleged racially discriminatory stop and frisk stated a claim under the District of Columbia Human Rights Act.
4. Whether a request for declaratory relief under 28 U.S.C. § 2201 constituted a separate cause of action.

Disposition

other