Summary
The United States District Court for the District of Maryland resolves motions to dismiss in Uchenna Egenti’s civil rights action arising from her arrest and detention following an incident at a BJ’s Wholesale Club. The court dismisses the Monell, Longtin, official-capacity, and specified state-law tort claims against the Town of Forest Heights and Prince George’s County, while allowing a negligence claim based on the alleged rough ride and declining to dismiss the remaining claims against Officer Buie. The opinion is dated March 4, 2026.
Court
United States District Court for the District of Maryland
Jurisdiction
United States District Court for the District of Maryland
Decision date
March 4, 2026
Docket number
8:25-cv-00948-LKG
Disposition
other
Questions Presented
- Whether the complaint plausibly alleged Monell and Longtin municipal-liability claims against the Town of Forest Heights and Prince George's County.
- Whether the complaint plausibly alleged official-capacity claims against the individual officers.
- Whether governmental immunity barred the state-law tort claims against the Town and County.
- Whether governmental immunity barred the negligence claim based on the alleged rough ride.
- Whether Officer Buie was entitled to public-official immunity for the state-law claims.
- Whether the complaint plausibly stated a malicious-prosecution claim against Officer Buie.
Holdings
- The complaint failed to state plausible Monell claims against the Town and County because it did not identify an official policy or custom attributable to either municipality that caused the alleged constitutional violations.
- Because the complaint failed to state a Monell claim, the Longtin claims against the Town and County and the official-capacity claims against the individual officers also failed.
- Governmental immunity barred the state-law claims for assault and battery, false imprisonment, intentional infliction of emotional distress, malicious prosecution, and abuse of process against the Town and County.
- The negligence claims against the Town and County based on the alleged rough ride were not dismissed on governmental-immunity grounds.
- Officer Buie was not entitled to dismissal of the state-law claims based on public-official immunity at the pleading stage.
- The complaint plausibly stated a malicious-prosecution claim against Officer Buie.
Court Document
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