Cheryl James v. Wilkes Barre City
2012 U.S. App. LEXIS 24592
| 3rd Cir. | 2012Background
- Officer Marshall transported Nicole James to hospital after she texted about suicide; parents consented to hospital evaluation reluctantly.
- Plaintiff alleged that Cheryl James was coerced to accompany Nicole via ambulance, effectively causing false imprisonment/arrest under §1983.
- District Court denied qualified immunity and allowed §1983 false arrest/imprisonment claims to proceed; district court later reversed for immunity on some claims.
- Court reviews denial of motion to dismiss de novo, focusing on whether a constitutional violation occurred and whether rights were clearly established.
- The court ultimately held no Fourth Amendment seizure or false imprisonment occurred, thus Officer Marshall is entitled to qualified immunity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a Fourth Amendment seizure occurred | James alleged show of authority forced participation | No seizure occurred due to lack of coercive show of force | No seizure; qualified immunity granted on false arrest claim |
| Whether Mrs. James was falsely imprisoned | Her detention in ambulance was unlawful | No detention without seizure; coerced consent not equivalent to false imprisonment | False imprisonment not established; qualified immunity applies |
| Whether the alleged actions violated clearly established rights | Officer violated clearly established rights | Rights not clearly established for this set of facts | Qualified immunity applicable; no clearly established constitutional violation |
Key Cases Cited
- Florida v. Bostick, 501 U.S. 429 (1991) (seizure requires show of authority that a reasonable person would submit to)
- Hodari D. v. California, 499 U.S. 621 (1991) (show of authority not a seizure unless compliance is compelled)
- United States v. Mendenhall, 446 U.S. 544 (1980) (no seizure when officer asks questions without coercive conduct)
- United States v. Drayton, 536 U.S. 194 (2002) (no seizure when passengers are asked questions without coercion)
- California v. Hodari D., 499 U.S. 621 (1991) (test for seizure is objective show of authority leading to submission)
- Brown v. United States, 448 F.3d 239 (3d Cir. 2006) (seizure requires showing of intentional restraint of movement)
- Hayes v. Florida, 470 U.S. 811 (1985) (seizure occurs when police threaten arrest after asking to accompany)
- Kernats v. O’Sullivan, 35 F.3d 1171 (7th Cir. 1994) (coercive pressure may constitute seizure in some contexts)
- Saucier v. Katz, 533 U.S. 194 (2001) (two-step qualified immunity analysis standard)
- Pearson v. Callahan, 555 U.S. 223 (2009) (practical approach to qualified immunity; prongs may be addressed in any order)
- Behrens v. Pelletier, 516 U.S. 299 (1996) (finality of denial of qualified-immunity on appeal)