Mbalaminwe Mwimanzi v. District of Columbia et al.

Summary

The District Court for the District of Columbia dismissed Mbalaminwe Mwimanzi’s claims arising from his detention, custodial intake, and visual body-cavity search after his probation was revoked. The court held that the complaint failed to plausibly allege a District of Columbia policy or custom causing the alleged constitutional violations. It also held that claims against the U.S. Marshals Service and the Department of Justice were barred by sovereign immunity and that Bivens does not provide a waiver of that immunity or permit claims against federal agencies.

Holdings

1. The complaint failed to state a claim against the District of Columbia because it alleged constitutional injuries but provided no nonconclusory facts plausibly showing that a District policy or custom caused those injuries.
2. The claims against the federal agencies were barred by sovereign immunity and had to be dismissed for lack of subject-matter jurisdiction; Bivens does not waive sovereign immunity and does not authorize constitutional damages claims against federal agencies.

Questions Presented

1. Whether the second amended complaint plausibly alleged that a District of Columbia policy or custom caused a constitutional violation sufficient to support municipal liability under 42 U.S.C. § 1983.
2. Whether constitutional damages claims against the U.S. Marshals Service and the U.S. Department of Justice were barred by sovereign immunity and the absence of a Bivens cause of action against federal agencies.

Disposition

dismissed