Grimes v. District of Columbia, No. 13-7038 (D.C. Cir. 2015)
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Plaintiff is the mother of Karl Grimes, a juvenile who was allegedly beaten to death at a detention facility. Plaintiff claimed that the District showed deliberate indifference to, and
reckless disregard for, her son’s safety, and that the District was negligent in hiring, training, and supervising its employees at the detention center in violation of District of Columbia
tort law, the Eighth Amendment, and 42 U.S.C. 1983. The district court granted the government’s motion for summary judgment, and denied as moot plaintiff’s cross-motion to strike the summary judgment motion and to disqualify the Attorney General of the District of Columbia based on an asserted conflict of interest. The court concluded that the district court should resolve a motion to disqualify counsel before it turns to the merits of any dispositive motion because a claim of counsel’s conflict of interest calls into question the integrity of the process in which the allegedly conflicted counsel participates. Therefore, the court concluded that the district court erred in the sequence in which it rendered its decisions. Accordingly, the court vacated the district court's grant of summary judgment and its denial of the motion to disqualify, and remanded for further proceedings.
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