Arroyo v. City of New York, 683 F. App'x 73

Background

Plaintiff Santia Arroyo alleged police removed her from her home on Dec. 20, 2011, transported her to Metropolitan Hospital under NY Mental Hygiene Law § 9.41, and later arrested her for possessing a firearm.
Police responded to a 911 call reporting possible elder abuse and that Arroyo was bipolar; they also spoke to the supervisor of the home attendant, who said Arroyo threatened her mother and kept a gun at home.
Officers observed Arroyo acting erratically and spoke with Arroyo’s mother, who said she could not leave her bedroom.
Officer Vega discovered a gun in Arroyo’s purse at the hospital (a fact later subject to suppression in criminal proceedings, but relied on here by officers).
Arroyo sued under 42 U.S.C. § 1983 (false arrest, malicious prosecution, excessive force, Monell municipal liability) and asserted related New York state-law claims; the district court granted summary judgment to defendants and declined supplemental jurisdiction over state claims.
The Second Circuit affirmed, holding officers had arguable probable cause and were entitled to qualified immunity; it also affirmed dismissal of other federal claims and the decision to decline supplemental jurisdiction.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
False arrest for removal under MHL § 9.41 and subsequent arrest for gun possession	Arroyo: officers lacked probable cause to detain her under MHL § 9.41 and to arrest her for possession; qualified immunity should not apply	Officers: they had identifiable reports, eyewitness supervisor statements, observations of erratic behavior, and a gun was found; at minimum arguable probable cause existed	Affirmed: officers entitled to qualified immunity because arguable probable cause supported removal and arrest
Malicious prosecution (§ 1983)	Arroyo: prosecution was baseless and officers are liable	Officers: qualified immunity applies because arguable probable cause existed at time of arrest	Affirmed: qualified immunity bars § 1983 malicious prosecution claim
Excessive force based on handcuffing at hospital	Arroyo: handcuffing during arrest was excessive	Officers: force (handcuffs) was reasonable; Arroyo suffered no physical injury and did not request removal	Affirmed: no genuine dispute of excessive force; summary judgment for defendants
Municipal liability (Monell)	Arroyo: City policies/customs led to constitutional violations	City: no evidence of a citywide policy or custom tied to Arroyo’s treatment	Affirmed: Arroyo failed to show a policy/custom causing the alleged violation
State-law claims / supplemental jurisdiction	Arroyo: state claims should proceed in federal court	Defendants: federal claims dismissed; district court may decline supplemental jurisdiction	Affirmed: district court permissibly declined to exercise supplemental jurisdiction over state claims

Key Cases Cited

Willey v. Kirkpatrick, 801 F.3d 51 (2d Cir. 2015) (standard of review for summary judgment)
Rodriguez v. Vill. Green Realty, Inc., 788 F.3d 31 (2d Cir. 2015) (summary judgment standard under Rule 56)
Escalera v. Lunn, 361 F.3d 737 (2d Cir. 2004) (definition of probable cause to arrest)
Figueroa v. Mazza, 825 F.3d 89 (2d Cir. 2016) (qualified immunity and arguable probable cause in false arrest context)
Zalaski v. City of Hartford, 723 F.3d 382 (2d Cir. 2013) (aroguable probable cause standard)
Betts v. Shearman, 751 F.3d 78 (2d Cir. 2014) (qualified immunity for § 1983 malicious prosecution with arguable probable cause)
Graham v. Connor, 490 U.S. 386 (1989) (objective reasonableness standard for excessive force)
Townes v. City of New York, 176 F.3d 138 (2d Cir. 1999) (suppression of evidence does not negate arguable probable cause for § 1983 purposes)
Littlejohn v. City of New York, 795 F.3d 297 (2d Cir. 2015) (Monell pleading and proof standards)
Monell v. Department of Social Services of the City of New York, 436 U.S. 658 (1978) (municipal liability requires policy or custom)