Adams v. Selhorst
2011 U.S. Dist. LEXIS 28106
D. Del.2011Background
- Adams was arrested on Oct. 4, 2007 on a harassment warrant based on a text message Adams allegedly sent.
- Officers learned the harassing text originated from Adams’s phone number; CJIS showed Adams had used the number in prior police matters.
- Adams turned herself in later that day; officers learned at CJIS that she had already been arraigned and released, then handcuffed her briefly before releasing upon learning the prior surrender.
- Only Officer Selhorst (not Doe 1/2) faced viable claims; unnamed officers were dismissed for lack of identification.
- Plaintiffs’ federal claims include §1983 and §1985/1986; state tort claims include slander, emotional distress, assault and battery, and trespass; the court granted summary judgment to defendants on most counts under applicable immunities.
- The court ultimately granted summary judgment for defendants on all claims and dismissed the case with prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether there was probable cause for false arrest | Adams asserts lack of probable cause and improper arrest. | Selhorst had probable cause based on the text and CJIS data. | Probable cause supported arrest; dismissal of false arrest claim prevailed for Selhorst. |
| Whether excessive force was used | Adams suffered excessive force in handcuffing. | Force was reasonable under the circumstances. | Excessive force claim dismissed; force deemed reasonable. |
| Whether there was malicious prosecution | Officers initiated charges for improper reasons. | Probable cause and prosecutorial independence negate malicious prosecution. | Malicious prosecution claim rejected; Monell/indirect liability not shown. |
| Whether Monell failure-to-train claim against the County/Officer Selhorst lies | County policy/training caused rights violations. | No named municipal defendant; no cognizable Monell claim against Selhorst. | Monell claim dismissed; no basis shown for deliberate indifference. |
| Whether conspiracy/§1985 and failure to intervene survive | There was a conspiracy and failure to intervene. | No evidence of conspiracy or failure to intervene. | §1985 and failure-to-intervene claims dismissed. |
Key Cases Cited
- Groman v. Township of Manalapan, 47 F.3d 628 (3d Cir.1995) (probable cause and reasonableness analysis in §1983 claims)
- Dowling v. City of Philadelphia, 855 F.2d 136 (3d Cir.1988) (false arrest requires probable cause at the moment of arrest)
- Beck v. Ohio, 379 U.S. 89 (1964) (probable cause standard for arrest based on known facts)
- Wilson v. Russo, 212 F.3d 781 (3d Cir.2000) (no independent investigation required; reasonableness of officer conduct)
- Saucier v. Katz, 533 U.S. 194 (2001) (qualified immunity—contours of right must be clear to a reasonable officer)
- Hunter v. Bryant, 502 U.S. 224 (1991) (qualified immunity tolerant of reasonable mistakes)
- Graham v. Connor, 490 U.S. 386 (1989) (objective reasonableness of force in Fourth Amendment excessive-force claims)
- City of Canton v. Harris, 489 U.S. 378 (1989) (deliberate indifference standard for failure-to-train claims)
- Napier v. City of New Castle, 407 F. App’x 578 (3d Cir.2010) (abuse of process vs. malicious prosecution distinction)