Plaintiff Takisha Reid alleged in a civil rights suit that New York City Police Department officer Gregory Howard sexually assaulted her while she was under Howard's supervision as a confidential informant.

U.S. Magistrate Judge Peggy Kuo of the Eastern District of New York granted the City's motion for summary judgment but not Howard's. New York City held no liability under the doctrine of respondeat superior as to complaints about Howard's conduct outside of the scope of his employment with the NYPD, the judge found.