M.T. v. Officer Craig Medley

Filing 32

MEMORANDUM OPINION. Signed by Magistrate Judge J. Mark Coulson on 11/19/2014. (dass, Deputy Clerk)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
M.T.,

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Plaintiff,

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v.

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OFFICER CRAIG MEDLEY, et al.,

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Defendants.

Civil No.: JMC-14-CV-424

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MEMORANDUM OPINION
This Memorandum Opinion addresses Defendants’ Motion to Bifurcate which requests
that the claims against Defendant Officer Craig Medley (“Defendant Officer Medley”) be
resolved first followed by any remaining claims against Defendants Annapolis Police
Department and City of Annapolis (“Municipal Defendants”). (ECF No. 30). Defendants argue
that bifurcation would be conducive to judicial economy and would avoid unfair prejudice to
Defendant Officer Medley. (Id.). The time for Plaintiff to file a reply lapsed and the Court
confirmed with Plaintiff’s Counsel that he does not intend to file any such responsive motion.
The Court has received and reviewed the Motion and applicable law thereto. No hearing is
deemed necessary. See Local Rule 105.6 (D.Md.). For the reasons presented below, the Court
GRANTS the Motion.
This case involves claims against Defendant Officer Medley for assault, battery, false
arrest, false imprisonment, and violations of 42 U.S.C. 1983 (ECF No. 1 at ¶¶ 23-46), related
claims against the Municipal Defendants (Id. at ¶¶ 46-57), and claims against all Defendants for
violations of Maryland’s Declaration of Rights (Id. at ¶¶ 58-61). It is well established that
Section 1983 cases, like this one, are good candidates for bifurcation because municipal liability
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is dependent on an initial finding that a government employee violated a plaintiff’s constitutional
rights.

See Okezie v. Prince George's Cnty., Md., No. CIV.A. CBD-13-0168, 2014 WL

1334188, at *1 (D. Md. Apr. 1, 2014) (citing Dawson v. Prince George's County, et al., 896
F.Supp. 537, 540 (D.Md.1995); Ransom v. Baltimore County, et al., 111 F.Supp.2d 704, 708
(D.Md .2000); Marryshow v. Bladensburg, et al., 139 F.R.D. 318, 318–19 (D.Md.1991); Beasley
v. Kelly, et al., CIV. A. DKC 10–0049, 2010 WL 3221848, at *3 (D.Md. Aug. 13, 2010)). It is
also well established that bifurcation of Section 1983 cases allows for the isolation of potentially
highly prejudicial evidence regarding municipal policies and customs which would be relevant to
the legal analysis of municipal liability but highly prejudicial to the individual government
employees. Id. at *2 (citing Beasley, 2010 WL 3221848, at *3).
For these reasons, bifurcation in this matter would preserve judicial economy and is the
best way to avoid the conflicts resulting in trying Plaintiff’s claims together. Further, bifurcation
would not prejudice either party; should the jury find in favor of Defendant Officer Medley, a
trial against Municipal Defendants would be unnecessary. For the foregoing reasons the Court
GRANTS the Motion.

An implementing Order will follow.
Date: November 19, 2014

/s/
J. Mark Coulson
United States Magistrate Judge

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