Muhammad v. City of New York

Background

Abdullah Muhammad asserted claims under 42 U.S.C. § 1983, a federal civil-rights statute, against individual police officers for allegedly using excessive force. He also asserted claims that officers failed to intervene and that the City of New York negligently hired, trained, or supervised them. In addition, he sought to hold the City and the New York City Police Department responsible for the individual officers’ conduct under a theory of employer responsibility. The opinion also notes that Muhammad withdrew claims for malicious prosecution and false arrest.

Claims Dismissed Before the Excessive-Force Ruling

The court dismissed the claims seeking to hold the City liable under employer responsibility because a municipality cannot be held liable under § 1983 on that theory. It also dismissed the claims against the New York City Police Department because the court described the Department as an agency that cannot be sued separately.

The court concluded that Muhammad had abandoned his failure-to-intervene and negligent hiring, training, and supervision claims because his opposition addressed only the excessive-force claim and the officers’ qualified-immunity defense. The court likewise dismissed any Equal Protection claim suggested by the amended complaint because Muhammad did not pursue that claim in his brief.

Excessive Force and Qualified Immunity

The defendants moved for summary judgment, which asks the court to rule without a trial when the evidence shows no genuine dispute over an important fact. They argued that any force used during the April 18, 2015 arrest was reasonable and that they were entitled to qualified immunity, a protection that can apply when an official did not violate a clearly established legal right.

The court found genuine factual disputes about the reasonableness of the force. The disputed matters included whether officers tackled Muhammad, whether he resisted arrest, and the circumstances of his injury. The arrest video did not resolve those disputes. Because the qualified-immunity question overlapped with the disputed facts about whether the force was reasonable, the court held that summary judgment could not be granted on that defense.

Disposition

The court granted the defendants’ motion for summary judgment in all respects except that it denied the motion as to Muhammad’s excessive-force claim under § 1983 and the individual defendants’ qualified-immunity defense. Thus, the excessive-force claim and that defense remained for further proceedings, while the other claims identified in the order were dismissed.