Johnson v. Holmes

4 Citing cases

  1. Benbow v. Ingram

    7:23-CV-292-M (E.D.N.C. May. 8, 2024)

    The Equal Protection Clause also “prohibits police officers from selectively enforcing laws based on race.” Ogunsula v. Md. State Police, No. CV ELH-20-2568, 2021 WL 6105503, at *29 (D. Md. Dec. 23, 2021) (quoting Johnson v. Holmes, 782 Fed.Appx. 269, (4th Cir. 2019) (citing Whren v. United States, 517 U.S. 806, 813 (1996))), reconsideration denied, No. CV ELH-20-2568, 2022 WL 3290713 (D. Md. Aug. 11, 2022). To sufficiently plead an equal protection claim for selective law enforcement, the complaint must allege “both discriminatory effect and that the officer's action was motivated by a discriminatory purpose.”

  2. Boas v. Graves

    Civil TJS-22-0979 (D. Md. Mar. 19, 2024)   Cited 1 times

    See Thompson v. Badgujar, No. DLB-20-1272, 2023 WL 6381509, at *3 (D. Md. Sept. 29, 2023) (citing Cent. Radio Co. Inc. v. City of Norfolk, Va., 811 F.3d 625, 634 (4th Cir. 2016) and Johnson v. Holmes, 782 Fed.Appx. 269, 276 (4th Cir. 2019)). Plaintiff has not plausibly alleged that Deputy Graves or Deputy Rishel's conduct was motivated by a discriminatory intent and that their actions had a discriminatory effect.

  3. Thompson v. Badgujar

    Civ. DLB-20-1272 (D. Md. Sep. 29, 2023)   Cited 4 times

    The standard for proving selective prosecution claims against prosecutors also applies to selective enforcement claims against police officers when a plaintiff alleges an officer made an enforcement decision on the basis of race. Johnson v. Holmes, 782 Fed.Appx. 269, 276-77 (4th Cir. 2019) (holding Equal Protection Clause prohibits police officers “from selectively enforcing laws based on race”) (citing Whren v. United States, 517 U.S. 806, 813 (1996));

  4. Maho v. Hankins

    Civ. No. 19-182 KK/SCY (D.N.M. May. 19, 2020)

    "A plaintiff may make this showing by (1) naming similarly situated individuals of a different race who were treated differently by law enforcement; or (2) providing statistics that address this question." Johnson v. Holmes, 782 F. App'x 269, 277 (4th Cir. 2019); see Blackwell, 496 F. App'x at 839 ("Statistical evidence can be used to show . . . discriminatory effect[.]"). A defendant's alleged "discriminatory purpose," in turn, "need not be the only purpose, but it must be a motivating factor in the decision" the plaintiff has challenged.