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D.C. Appellate Court Reverses $2.3 Million Wrongful Imprisonment Award

The District of Columbia’s Court of Appeals has reversed a judgment against the D.C. government based upon the municipal liability standard set forth in Monell v. Dept. of Social Services, 436 U.S. 658 (1978). According to the appellate court, the plaintiff, who had been wrongfully jailed following a parole revocation, failed to show that the violation of his rights resulted from a municipal policy or custom, shielding the District from liability for the improper acts of its employees.

The Court of Appeals wrote that “[t]he District of Columbia Board of Parole revoked plaintiff Charles Singletary’s parole based primarily on unreliable multiple-hearsay testimony. This court later determined that the evidentiary basis for his parole revocation failed to satisfy the requirements of the Due Process Clause.”

Singletary filed suit against the D.C. government under 42 U.S.C. § 1983, arguing “that the District bore responsibility for the Board’s unconstitutional revocation decision. The district court found the District liable, and a jury awarded $2.3 million in damages for the period of Singletary’s confinement following the revocation of his parole.” [See: PLN, Sept. 2012, p.30].

The U.S. Supreme Court’s decision in Monell is the controlling case for determining municipal liability. To prevail, a plaintiff must show that a policy or custom of a municipal body was responsible for the violation of the plaintiff’s rights. The District argued that “it had no general policy or custom of basing parole-revocation decisions on evidence falling below the constitutional threshold for reliability,” and, therefore, “it cannot be held responsible for the Board’s revocation decision.”

The appellate court noted that the revocation of Singletary’s parole by the D.C. Board of Parole did not mean the Board had “final policymaking authority” so as to establish municipal liability under Monell. Referring to the Board, the Court of Appeals wrote, “Such authority was lacking here. Neither the Board as a whole nor the three-member quorum that revoked Singletary’s parole was authorized to promulgate general rules or other policies.”

The appellate court concluded that “Singletary suffered a violation of his constitutional rights when the Board revoked his parole based on evidence lacking adequate indicia of reliability. He served a lengthy period in confinement pending the resolution of that constitutional claim.” However, as the District did not have a custom or policy that caused the violation of his constitutional rights, the trial court’s judgment and $2.3 million jury award were vacated. Singletary’s petition for writ of certiorari to the U.S. Supreme Court was denied on March 23, 2015. See: Singletary v. District of Columbia, 766 F.3d 66 (D.C. Cir. 2014), cert. denied. 

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Related legal cases

Singletary v. District of Columbia

Monell v. Department. of Social Services