Kevin Morgan v. Charles County Sheriff's Office, et al.; Kevin Morgan v. L. Leapley, et al.

Summary

The United States District Court for the District of Maryland consolidated two civil rights actions brought by Kevin Morgan concerning an alleged use of excessive force during the collection of a DNA sample at the Charles County Detention Center. The court dismissed the claims against the Charles County Sheriff's Office and Charles County Detention Center, granted summary judgment to the individual officers, and denied Morgan's motions for counsel, discovery, and leave to amend. The opinion addresses excessive-force claims, municipal liability under 42 U.S.C. § 1983, summary judgment, and related procedural motions.

Holdings

1. A pretrial detainee's excessive-force claim is governed by an objective-reasonableness standard, and the officers' physical restraint of Morgan during the DNA collection was objectively reasonable under the circumstances.
2. When a video recording clearly contradicts a party's version of events so that no reasonable jury could believe that version, the court may decline to adopt it for summary-judgment purposes.
3. The Charles County Detention Center is not a person subject to suit under 42 U.S.C. § 1983 and was properly dismissed.
4. The Charles County Sheriff's Office was entitled to dismissal on Eleventh Amendment immunity grounds because Maryland sheriffs and deputy sheriffs are state, rather than county, officials for purposes of Maryland law.
5. Morgan's proposed amendment adding Charles County was futile because he alleged no policy or custom causing the constitutional injury and § 1983 does not impose respondeat superior liability on municipalities.
6. Morgan failed to state a supervisory-liability claim because he did not adequately allege the elements of supervisory knowledge, deliberate indifference or tacit authorization, and an affirmative causal link.
7. The court declined supplemental jurisdiction over any state tort claims after dismissing the federal claims and dismissed those claims without prejudice.

Questions Presented

1. Whether the officers' use of force during the execution of the DNA-collection warrant was objectively unreasonable under the Fourteenth Amendment.
2. Whether the video evidence so clearly contradicted Morgan's account that summary judgment was appropriate despite conflicting affidavits.
3. Whether the Charles County Detention Center was a suable person under 42 U.S.C. § 1983.
4. Whether the Charles County Sheriff's Office was immune from Morgan's federal suit under the Eleventh Amendment.
5. Whether Morgan stated a viable § 1983 municipal-liability or supervisory-liability claim.
6. Whether Morgan's proposed amendment adding Charles County as a defendant would be futile.
7. Whether Morgan's state-law claims should remain in federal court after dismissal of the federal claims.
8. Whether Morgan established exceptional circumstances warranting appointment of counsel or demonstrated a need for additional discovery under Rule 56(d).