A recent ruling from the District Court for the District of Columbia has allowed some claims to proceed in a case where a customer alleges he was injured by security guards at a Safeway store. The court's decision affects the plaintiff, Lafayette Davis, who is seeking $4 million in damages after sustaining a broken leg during an encounter with the guards.
The case, Davis v. Faith of Life Protection Services, Inc., was filed on September 30, 2026, under Civil Action No. 2025-1779. Judge Amy Berman Jackson presided over the case, which involved multiple defendants, including Safeway, Protos Security, and Faith of Life Protection Services.
The dispute arose from an incident on July 29, 2024, when Davis, a regular customer at the Safeway store located at 415 14th Street SE in Washington, D.C., was allegedly assaulted by security guards employed by Faith of Life. Davis claims that after he was told he would be barred from the store for five years, he returned to speak with the manager. During this visit, he alleges that guards Somerville and McCoy jumped on him and threw him to the ground, resulting in a broken leg.
Davis's complaint includes several claims against the defendants, including battery, false imprisonment, and malicious prosecution. The case reached the District Court after the defendants filed motions to dismiss various claims. Specifically, Safeway and Protos moved to dismiss claims related to Section 1983, which involves constitutional violations, arguing that private entities cannot be held liable under a respondeat superior theory.
In her ruling, Judge Jackson granted in part and denied in part the motions to dismiss. The court ruled that the battery, false imprisonment, and false arrest claims against Safeway and Protos would move forward, while the Section 1983 claims and others, including malicious prosecution and negligent hiring, would be dismissed.
The court stated, "Counts I and II will be dismissed because, under section 1983, private entities are not liable under a respondeat superior theory."
Additionally, the court found that Davis had sufficiently alleged battery under a theory of respondeat superior, allowing that claim to proceed against all defendants. The ruling emphasized that at this stage of litigation, the court must draw all inferences in favor of the plaintiff, and since the claim is moving forward against Faith of Life, it will also proceed against Protos and Safeway.
As for the impact of this ruling, it allows Davis to continue pursuing his claims against the security companies and the individuals involved. This case highlights the legal responsibilities of security personnel and their employers in situations involving customer interactions. The court's decision may set a precedent for similar cases where private security guards are involved in alleged misconduct.
Looking ahead, the case may still be appealed, particularly regarding the dismissed claims. The defendants, especially Safeway and Protos, may seek to challenge the court's findings on the battery and related claims as the case progresses. Meanwhile, the claims against Faith of Life remain pending, and the outcome could influence the legal landscape surrounding the responsibilities of private security firms.