Catrena Green v. Adam Throckmorton
2012 U.S. App. LEXIS 11930
| 6th Cir. | 2012Background
- Green stopped for failing to dim high beams; arrest for DUI based on field sobriety tests; urine test later negative and charges dropped.
- Green sued Trooper Throckmorton under §1983 alleging Fourth Amendment violations for detention and arrest without/without probable cause.
- District court granted Throckmorton summary judgment on both claims.
- On appeal, court held detention for sobriety tests and arrest issues must be decided by a jury due to disputed facts and challenged credibility of officer observations.
- Court remands for further proceedings consistent with opinion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Detention for field sobriety tests violated Fourth Amendment | Green argues lack of reasonable suspicion before detaining for tests | Throckmorton contends totality of circumstances supported reasonable suspicion | Jury must decide; not law as a matter of law |
| Qualified immunity for detention | Qualified immunity not available given disputed facts | Officer acted with reasonable belief under existing law | Jury must decide whether liability exists due to disputed facts |
| Probable cause for arrest for DUI | Test results and video create ambiguity; no clearly established probable cause | Facts supported probable cause based on test performance | Jury must decide whether probable cause existed given ambiguous evidence |
| Credibility and Miller framework applicability | Miller requires jurors to assess credibility when exculpatory evidence appears | Miller applied only to probable cause/arrest context as argued by Throckmorton | Miller’s reasoning applies to reasonable-suspicion as well; jury should decide under disputed facts |
Key Cases Cited
- Scott v. Harris, 550 U.S. 372 (U.S. 2007) (video evidence governs summary judgment analysis where applicable)
- Miller v. Sanilac County, 606 F.3d 240 (6th Cir. 2010) (subsequent drug/alcohol test can undermine officer observations; jury could find lack of probable cause or truthfulness)
- United States v. Bell, 555 F.3d 535 (6th Cir. 2009) (probable-cause requires traffic-violation-based stop to justify continued detention only for citation issuance)
- United States v. Perez, 440 F.3d 363 (6th Cir. 2006) (reasonable suspicion must be grounded in specific and articulable facts)
- Crockett v. Cumberland College, 316 F.3d 571 (6th Cir. 2003) (probable-cause assessment based on all facts known to officer at the time)