The United States Court of Appeals for the District of Columbia (DC) Circuit held that a lower court improperly granted prison officials summary judgment on a former guard's wrongful termination claims.
On the morning of June 4, 2006, the District of Columbia Jail (DCJ) was on lockdown because two prisoners escaped the day before. At that time, transgender prisoner Derrick Brown, who the court described as "a conniving prisoner," was serving the third of fifteen weekends for simple assault and was scheduled for release at noon.
Brown was agitated because his release was slowed by the lockdown. He became argumentative and abusive toward guard Stephen Amobi. A verbal altercation between them soon escalated into a nose-to-nose shouting match.
Amobi tried to retreat, but Brown blocked his path. Brown saw Warden Robert Clay, Deputy Warden Stanley Waldren and Major Elbert White conducting a fire and safety inspection. He later admitted that he wanted to lure Amobi into attacking him so he could file suit and "get some money."
Brown punched Amobi on his right forearm and Amobi immediate retrained Brown, forcing him against the wall. As Brown had hoped, the approaching officials saw Amobi's reaction but not the assault that precipitated it.
The officials ordered Amobi to release Brown and ignored his plea that he was acting in self-defense. White ordered Amobi not to speak until instructed to do so.
Amobi was immediately placed on administrative leave. An internal affairs (IA) investigation ignored exculpatory evidence from witnesses who had actually seen the incident or heard Brown boast that he had just set up a lawsuit.
IA Director Wanda Patten and investigator Valerie Beard falsely claimed that they interviewed Brown, and he wanted to press criminal charges. Later events revealed that this interview was "pure fiction."
Incriminating incident reports were disclosed to police, but none of the exculpatory reports were disclosed. Amobi was arrested, charged with simple assault and released.
Amobi was summarily terminated on July 12, 2006 on the basis of the fictional interview of Brown by Patten and Beard. Amobi challenged his termination.
Following an August 3, 2006 hearing, Hearing Officer Phuoc Nguyen determined that Amobi acted in self-defense and recommended reinstatement. Department of Corrections (DOC) Director Devon Brown disagreed. Under pressure from DOC officials, Nguyen reconsidered and recommended termination. Amobi appealed but the appeal was never resolved. Amobi demanded arbitration pursuant to his union's collective bargaining agreement (CBA).
The criminal prosecution stalled in August 2006, but was reopened in October 2006, after the United States Attorney's Office was pressured by DOC officials to refile the charge.
The government's case fell apart when Brown testified at trial. He "provided a damning, self-inculpatory account of the artifice he employed during the June 2006 assault."
Exactly one year after the incident, the trial court found Amobi not guilty "following Brown's bombshell testimony." Amobi requested that he be reinstated immediately. District Attorney Repunzelle Johnson also counseled DOC Director Brown to reinstate Amobi, noting numerous discrepancies in the case against him. The director refused to reinstate him.
Following October 2 & 3, 2007 arbitration hearings, an arbitrator concluded that Amobi acted in self-defense and that he was summarily dismissed without cause. The arbitrator ordered that Amobi be reinstated with full backpay and benefits and that DOC correct, remove, or destroy all records related to Amobi's summary removal.
Amobi and his wife brought federal suit against the District, DOC and several DCJ officials. They alleged claims of conspiracy, false arrest, malicious prosecution, defamation, intentional infliction of emotional distress (IIED), due process violations, aiding and abetting, and loss of consortium. The district court granted Defendants summary judgment.
The Court of Appeals for the DC Circuit reversed the grant of summary judgment on Amobi's false arrest, malicious prosecution and IIED claims, finding that material factual disputes precluded judgment for Defendants. See: Amobi v. District of Columbia Department of Corrections, 755 F.3d 980 (D.C. Cir. 2014).
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Related legal case
Amobi v. District of Columbia Department of Corrections
|755 F.3d 980 (D.C. Cir. 2014)
|Court of Appeals