Juvenile brought action against District of Columbia and police officers alleging negligence and excessive force arising from his being bitten by police dog that officers released into house without a canine warning to search for potentially armed juvenile suspects during a burglary call.
The Superior Court granted summary judgment for District of Columbia and officers. Juvenile appealed.
The Court of Appeals held that:
- Juvenile could use defense expert’s affidavit on standard of care about deploying police dogs on juvenile suspects at summary judgment stage;
- Factual issues on any deviation from standard of care and causation precluded summary judgment on negligence claims against officers;
- Sovereign immunity barred claims of negligent hiring, training, and supervision against District of Columbia;
- Officers had qualified immunity from excessive force claims; and
- District of Columbia did not have Monell liability on excessive force claims.