Barrett v. PAE Government Services, Inc. (Traxler 9/15/2020): The Fourth Circuit affirmed the district court’s grant of summary judgment in favor the defendants—two Arlington County, Virginia police officers and one of the County’s mental health examiners—after the defendants were sued under 42 U.S.C. § 1983. The plaintiff’s Section 1983 claim alleged that the “defendants unlawfully seized and detained her for a mental health evaluation in violation of the Fourth Amendment and falsely imprisoned her in violation of Virginia state law.” 2020 WL 5523552, at *1 (4th Cir. Sept. 15, 2020). The plaintiff also sued her employer. On appeal, the Fourth Circuit concluded that the plaintiff’s detainment was reasonable based on the officers’ and mental health examiner’s belief that the plaintiff was a danger to herself and others. Further, the Fourth Circuit concluded that the officers had the requisite legal justification to detain the plaintiff and followed the proper procedure for detaining her under Virginia law. Finally, the conclusory allegations in the plaintiff’s complaint were insufficient to support a plausible inference of conspiracy between the Arlington County officers, the County’s mental health examiner, and employees of the plaintiff’s employer under state or federal law. Therefore, the court affirmed the district court’s order. Full Opinion
Jessica Thompson