Court of Appeals Rejects Claims for False Imprisonment, Malicious Prosecution, and Unjust Imprisonment Brought by Former Prisoner Whose Conviction Was Vacated
On May 10, 2012, the District of Columbia Court of Appeals decided DeWitt v. District of Columbia, No. 10-CV-510, slip op. (D.C. May 10, 2012) in which it considered common law claims for false imprisonment and malicious prosecution and a statutory claim for unjust imprisonment under the District of Columbia’s Unjust Imprisonment Act, D.C. Code §§ 2-421 to -424. The plaintiff in this case was convicted of various criminal charges and subject to a lengthy prison sentence. DeWitt, slip op. at 2. More than a decade later, he submitted a motion to vacate his conviction on the grounds of newly discovered exculpatory evidence that substantially undermined the government’s case against him. Id. The trial court vacated the conviction and ordered a new trial based on its findings that the evidence showed that it was more likely than not that the plaintiff was innocent but that the evidence fell short of clearly and convincingly showing his innocence. Id. The government declined to re-try the case and the plaintiff was released from prison. Id. The plaintiff then filed a civil action against the District of Columbia and four officers of the Metropolitan Police Department alleging claims for false imprisonment, malicious prosecution, and unjust imprisonment arising from his prosecution and imprisonment. Id. at 3. The trial court granted summary judgment for the defendants. Id. at 3. On appeal, the key issue with respect to the false imprisonment and malicious prosecution claims was whether there was probable cause to arrest and prosecute the plaintiff. Id. at 4-10. The Court of Appeals ruled that, even setting aside any evidence that the plaintiff alleged had been manipulated or otherwise corrupted by the defendants, there was sufficient evidence during the relevant time period to show probable cause, including several witness identifications of the plaintiff. Id. at 7-9. It further found that there was no basis for concluding that the plaintiff was prosecuted maliciously because practically all of the exculpatory evidence that served as the basis for vacating the plaintiff’s conviction was discovered after he had already been tried. Id. at 9-10. With respect to the unjust imprisonment claim, the issue on appeal was whether the claim was barred by the doctrine of collateral estoppel. Id. at 10-17. The Court of Appeals ruled that it was barred because the trial court in vacating the plaintiff’s conviction explicitly found that the evidence fell short of clearly and convincingly showing the plaintiff’s innocence. Id. The Court of Appeals ruled that this finding precluded the plaintiff from proving an essential element of his unjust imprisonment claim; specifically, “that, based on clear and convincing evidence, he did not commit any of the acts charged.” Id. at 10 (quoting D.C. Code § 2-412). Accordingly, the Court of Appeals affirmed the trial court’s grant of summary judgment to the defendants. Id. at 17.