Hurd v. District of Columbia, No. 20-7003 (D.C. Cir. 2021)
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Four years after his release from prison, and after completing three years of supervised release, plaintiff was told he would have to serve another 27 months in jail based on an erroneous release from prison because he had a consecutive misdemeanor to serve. Plaintiff filed a writ of habeas corpus and the district court ruled that he must serve the remainder of his sentence. Plaintiff appealed, but the district court failed to act on the appeal until December 2013, at which point it dismissed the petition as moot because plaintiff had been released from jail upon completion of his sentence.
Plaintiff then filed a 42 U.S.C. 1983 action alleging that his spontaneous incarceration deprived him of due process under the Fifth Amendment. The district court dismissed the case based on claim preclusion in light of plaintiff's prior unsuccessful habeas corpus action. The DC Circuit reversed and, on remand, the district court granted summary judgment for the District.
The DC Circuit affirmed the district court's judgment that plaintiff failed to establish a pattern of constitutional violations or to demonstrate deliberate indifference. The court explained that plaintiff's evidence fails to show either that the District had a relevant custom of unconstitutional actions or that the District acted with deliberate indifference. However, the court vacated the entry of summary judgment for the District on the claim of unconstitutional policy because the nature and contours of the alleged policy present a number of disputed issues of material fact. Accordingly, the court remanded for further proceedings.
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