Danielle Brown v. State of Maryland, et al.

Summary

The United States District Court for the District of Maryland granted Defendants’ motion to bifurcate Plaintiff’s claims against an individual police officer from her Monell claims against the Baltimore Police Department. The court also stayed discovery concerning the Monell claims until the underlying constitutional claims were resolved. It concluded that bifurcation would promote judicial economy, conserve resources, and reduce the risk of juror prejudice.

Holdings

1. The court may bifurcate the individual-officer claims from the Monell claims because doing so promotes judicial economy, conserves resources, permits the individual claims to proceed more quickly, and reduces the risk of juror prejudice from unrelated excessive-force evidence.
2. The court may stay discovery directed to the Monell claims until the underlying constitutional claims against Officer Murray have been resolved.

Questions Presented

1. Whether the trial of Brown's individual constitutional claims against Officer Murray should be bifurcated from the Monell claims against BPD.
2. Whether discovery concerning the Monell claims should be stayed until the underlying constitutional claims against Officer Murray are adjudicated.

Disposition

other