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Biscoe v. Arlington County

738 F.2d 1352, 238 U.S. App. D.C. 206 (1984)

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Biscoe v. Arlington County

United States Court of Appeals for the District of Columbia Circuit

738 F.2d 1352, 238 U.S. App. D.C. 206 (1984)

Facts

Michael Kyle was a police officer employed by Arlington County, Virginia (defendant). Kyle pursued Lyntellus Brooks, a suspected bank robber, from Virginia into the District of Columbia. In the District of Columbia, Kyle caught up to Brooks but was unable to arrest him. Brooks got back into his car and, while Kyle was pursuing Brooks, Brooks’s car collided with that of Alvin Biscoe (plaintiff), a Maryland resident, severely injuring Biscoe. Biscoe filed suit against Kyle and Arlington County in federal court in the District of Columbia. After trial, the jury awarded Biscoe $4 million, finding that Kyle had been negligent and that Arlington County was liable on a theory of respondeat superior and for negligently training and supervising Kyle. Arlington County appealed, arguing that it was immune from suit under Virginia law.

Rule of Law

Issue

Holding and Reasoning (Edwards, J.)

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