Candi Walz v. Brian Randall, 2 F.4th 1091

In Sept. 2016, 15‑year‑old Tanner Walz was arrested after Angela’s 16‑year‑old daughter Haley reported a sexual assault; Haley underwent a SANE exam and a Child Protection Center (CPC) interview describing repeated nonconsensual acts.
Deputies Randall and Quandt reviewed Haley’s medical report and CPC interview (which were largely consistent), photographed a text message about rumors, and interviewed Tanner at the station.
Tanner initially denied being at Haley’s house, then admitted he was there and gave an account asserting (inconsistently) that the sex was consensual or that Haley initiated/forced him.
Deputies arrested Tanner and the State charged him with third‑degree sexual abuse; Tanner’s custodial statements were later suppressed and the charges were dismissed.
Tanner and his parents sued under 42 U.S.C. § 1983 (false arrest, reckless investigation/substantive due process) and Iowa tort law (false arrest, malicious prosecution); the district court granted summary judgment to defendants.
The Eighth Circuit affirmed, holding officers had probable cause to arrest, did not act with conscience‑shocking recklessness, and therefore were entitled to summary judgment (municipal liability dismissed for lack of individual liability).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Fourth Amendment / probable cause (false arrest)	Walz: deputies lacked probable cause; relied on inconsistent or vague victim statements and failed adequate investigation	Deputies: had detailed, consistent reports from victim, corroborating physical/medical exam, and Tanner’s inconsistent statements	Held: Probable cause existed; arrest lawful; summary judgment for deputies
Fourteenth Amendment / reckless investigation (substantive due process)	Walz: deputies acted recklessly/failed to investigate exculpatory leads and should have doubted Haley because of age/inconsistencies	Deputies: investigation consisted of medical report, CPC interview, evidence collection, and interviewing witnesses and Tanner; no coercion or purposeful disregard of exculpatory evidence	Held: No conscience‑shocking recklessness; summary judgment for deputies
State torts (false arrest, malicious prosecution)	Walz: state claims because arrest and prosecution unsupported by probable cause	Deputiffs: Iowa law mirrors federal probable cause standard; probable cause existed	Held: State claims fail for lack of probable‑cause element; summary judgment for deputies

Clay v. Conlee, 815 F.2d 1164 (8th Cir. 1987) (officers may rely on victim’s account absent indicators of unreliability)
Kuehl v. Burtis, 173 F.3d 646 (8th Cir. 1999) (officers must conduct a reasonably thorough investigation before arrest in some circumstances)
District of Columbia v. Wesby, 138 S. Ct. 577 (2018) (probable‑cause and reasonableness judged from standpoint of an objectively reasonable officer)
Gilmore v. City of Minneapolis, 837 F.3d 827 (8th Cir. 2016) (arguable probable cause can exist amid conflicting information)
Borgman v. Kedley, 646 F.3d 518 (8th Cir. 2011) (law enforcement may rely on victim’s veracity)
Maryland v. Pringle, 540 U.S. 366 (2003) (probable cause examined from events leading up to arrest, objectively)
Akins v. Epperly, 588 F.3d 1178 (8th Cir. 2009) (elements indicating conscience‑shocking recklessness in investigations)