April Smith v. Jason Munday, 848 F.3d 248

Background

On March 10, 2009, a confidential informant (CI) purchased crack and identified the seller as "April Smith," a "skinny" Black female; audio and video recordings failed to capture a clear ID.
Detective Munday later searched police/criminal databases and located April Yvette Smith — a Black woman in Lincoln County with prior drug-sale convictions — among multiple individuals sharing that name.
Nine months after the CI purchase, Munday obtained an arrest warrant for April Yvette Smith; officers Greene and Lesassier arrested her at home on December 22, 2009.
Smith was held ~80 days, lost her job, and charges were ultimately dismissed; she sued under 42 U.S.C. § 1983 and state tort law, alleging unconstitutional arrest/prosecution without probable cause.
The district court granted summary judgment for defendants, finding probable cause supported the warrant; the Fourth Circuit reversed in part, holding Munday lacked probable cause and is not entitled to qualified immunity, affirmed dismissal as to the police department and affirmed that the arresting officers executing a facially valid warrant were proper defendants for false arrest claim.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether probable cause supported Munday’s warrant application	Munday had no evidence linking April Yvette Smith to the CI transaction beyond shared name, race, gender, and prior convictions, so the warrant lacked probable cause.	The totality of circumstances (name, race, gender, local residence, prior drug convictions, and physical description) gave at least a reasonable basis for probable cause.	Reversed district court: warrant lacked probable cause (no individualized link to the crime).
Whether Munday is entitled to qualified immunity	Munday’s warrant application was so lacking in indicia of probable cause that reliance on it was objectively unreasonable.	A neutral magistrate issued the warrant and reasonable officers could disagree; this is a gray area entitling Munday to qualified immunity.	Qualified immunity denied as to Munday (application was so deficient that belief in probable cause was unreasonable).
Liability of arresting officers (Greene & Lesassier) for false arrest	Smith argued her arrest was unlawful because underlying warrant lacked probable cause.	Arresting officers executed a facially valid warrant and reasonably relied on it.	Affirmed for arresting officers on false-arrest claim (execution of a facially valid warrant shields them).
Municipal/departmental liability and state-law claims	Smith asserted supervisory, negligent-supervision, and state tort claims based on constitutional violation.	Defendants argued no constitutional violation; police department not a suable entity under NC law.	Remanded for district court to reconsider state-law and supervisory claims in light of finding against Munday; dismissal of Lincolnton Police Department affirmed.

Key Cases Cited

Illinois v. Gates, 462 U.S. 213 (totality-of-circumstances test for probable cause)
Malley v. Briggs, 475 U.S. 335 (no qualified immunity when warrant affidavit is so lacking in indicia of probable cause that belief is unreasonable)
Messerschmidt v. Millender, 565 U.S. 535 (deference to neutral magistrate and limits to that deference)
United States v. Leon, 468 U.S. 897 (good-faith exception and magistrate deference principles)
Durham v. Horner, 690 F.3d 183 (probable-cause and qualified-immunity analysis when investigator used databases and a grand jury returned indictments)
Thompson v. Prince William County, 753 F.2d 363 (officer may have probable cause when he reasonably connects a suspect to a controlled buy)