950 F. Supp. 2d 285
D. Mass.2013Background
- Chapman sued three Marblehead police officers (Finnegan, Peralta, Brady), the Chief of Police Picariello, and the Town of Marblehead under 42 U.S.C. §1983 for false arrest and related claims arising from his April 1, 2009 domestic assault arrest; Chapman, age 62, faced a 22-year-old accuser, Phelan, who reported the incident and alleged Chapman grabbed her throat.
- Phelan called 911; officers were told Chapman kept firearms at his residence and would meet Phelan in front of his home.
- Officers Finnegan and Peralta arrested Chapman after speaking with him and observing Phelan’s account and visible injuries; Chapman denies the assault.
- Chapman was processed at the Marblehead Police Station (approximately 30–45 minutes) and then transferred to Essex County House of Correction; he injected his diabetes medication with EMTs later retrieving it.
- Chapman asserted municipal liability (Monell) and supervisory liability against Picariello, and pursued false arrest, failure to investigate, and Eighth Amendment medical-care claims; the court granted summary judgment for the defendants on all claims.
- The court noted Chapman’s failure to cite admissible evidence in response to Rule 56.1 statements and proceeded to assess the merits on the undisputed record.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Marblehead can be liable under §1983 about an official policy or custom | Chapman argues a policy/custom caused violations | Town failed to identify a policy or widespread custom | No policy or custom shown; town granted summary judgment |
| Whether Picariello can be liable as a supervisor | Picariello supervised the officers’ conduct | No link between Picariello and the arrest conduct | No supervisory liability; Picariello granted summary judgment |
| Whether Chapman’s arrest violated constitutional rights via false arrest | Arrest lacked probable cause given Chapman’s medical condition | There was probable cause based on Phelan’s report and injuries | Probable cause supported; false arrest claims dismissed |
| Whether Chapman received adequate medical care; deliberate indifference claim | Officers failed to refrigerate diabetes medication; delay harmed Chapman | Delay and refrigeration issue were not deliberate indifference; medical care adequate | No deliberate indifference; medical-care claim dismissed |
Key Cases Cited
- Monell v. Dept. of Social Servs. of City of New York, 436 U.S. 658 (U.S. Supreme Court 1978) (municipal liability requires policy or custom)
- Board of County Commissioners of Bryan County v. Brown, 520 U.S. 397 (U.S. Supreme Court 1997) (monetary liability requires moving force of the violation)
- Young v. City of Providence, 404 F.3d 4 (1st Cir. 2005) (policy or custom analysis for §1983 claims against municipalities)
- Ashcroft v. Iqbal, 556 U.S. 662 (U.S. Supreme Court 2009) (supervisor liability requires personal involvement; no vicarious liability in §1983 actions)
- Graham v. Connor, 490 U.S. 386 (U.S. Supreme Court 1989) (two essential elements for §1983 claims; objective reasonableness in searches/arrests)