In 2015, Lyle Dotson, a black high school student visiting New Orleans on a field trip, was tackled by police officers when he became separated from his group. They accused him of following an undercover narcotics officer and wrongfully levied charges of battery against him, and he was sent to the Orleans Parish Prison, where he endured inhumane conditions while awaiting hearing. Once out on bail, his father, Olon Dotson, hired a team of attorneys to prove that the charges against Lyle were false and to have his arrest expunged. A year after the arrest, they filed a federal lawsuit against the Louisiana State Police.
The MacArthur Justice Center handled the lawsuit, which went to trial in January 2018. Of the four officers who were defendants at the trial, only one was found guilty of violating Lyle’s rights by continuing to detain him after they no longer had reasonable suspicion to do so. The jury also awarded no compensation to the plaintiff However, the jury had only one black juror (the rest were white), and the Dotsons contested the verdict on the basis of purposeful discrimination by the prosecution, in violation of constitutional law. A retrial was granted, but the plaintiffs reached an out of court settlement before it was held (Harp, 2018).
Substantive Law Aspects of the Case
The case titled Dotson et al v. Edmonson et al is civil rights suit brought under Section 1983, the federal statute that allows citizens to sue government employees for civil rights violations. This provision of the Civil Rights Act of 1871 states, “Every person who under color of any statute, ordinance, regulation, custom, or usage, of any State…subjects, or causes to be subjected, any citizen of the United States…to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured” (42 U.S.C. § 1871). Since 1871, Section 1983 has been used to provide private citizens with civil recourse against abuses by those acting with legally granted authority (or purporting to act with legal authority). It was originally called the “Ku Klux Klan Act” in direct response to the Klan’s campaign of violence and terror during the Reconstruction Period. The Act has transformed into a species of tort liability by which people deprived of their constitutional rights have been able to recover damages or equitable relief (Forsythe).
According to the statute, only “persons” are subject to liability; municipalities and local governments are considered “persons” who can be sued for damages and prospective relief, although the United States government cannot be subject to suit. Individual employees of federal, state, and local government can also be sued “in their individual capacities” (Forsythe). A successful Section 1983 suit must be able to establish a causal connection between the defendant’s actions and the resultant harm. Furthermore, in order to hold local government liable, the harm must be the result of action “on the part of the government entity that implemented or executed a policy… officially adopted and promulgated by that body’s officers” (Forsythe). This limitation on the attribution of liability goes against the doctrine of respondeat superior, which states that parties are responsible for the acts of their agents. For a Section 1983 suit to prevail against a government entity, it must be shown to implement a policy “so deficient…that the policy itself is a repudiation of constitutional rights and is the moving force of the constitutional violation” (Faberman, 1993, p. 101).
Personal Reflection
I believe that the plaintiffs had a strong case against the Louisiana Police Department, which along with six individuals was one of the defendant parties in the lawsuit. I believe that if the case had gone to retrial as planned, the defense would have been able to argue that Lyle’s deprivation of constitutional rights followed as a consequence of the LSP’s “deficient” policy of failing to properly train its officers.
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