Christopher Stoner v. Eugene Watlingten
2013 U.S. App. LEXIS 22586
| 8th Cir. | 2013Background
- Stoner was arrested in Arkansas on suspicion of possessing weapons with a purpose to employ them against a person under Ark. Code Ann. § 5-73-120(a) after officers found firearms in his trunk.
- Two factual disputes existed: whether the firearms were loaded at the time and the precise location of the firearms in the trunk.
- Stoner presented the firearms to Watlingten during the stop, and Stoner was jailed for about four hours before charges were dropped by the prosecutor on grounds that he was on a journey defense.
- The district court denied summary judgment on the false-arrest claim, finding a genuine issue of material fact as to probable cause.
- On appeal, Watlingten challenged the denial, arguing qualified immunity; the panel reviewed de novo the qualified-immunity issue.
- The court held that, viewing facts in Stoner’s favor, Watlingten violated the Fourth Amendment by arresting without probable cause and that the right was clearly established at the time.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Probable cause for arrest under § 5-73-120(a) | Stoner | Watlingten | Arrest violated a constitutional right; no probable cause based on unloaded weapons |
| Whether the Fourth Amendment right was clearly established | Stoner | Watlingten | Right not clearly manageable only with ambiguity; it was clearly established that arrest without probable cause violates the Fourth Amendment |
| Statutory interpretation of § 5-73-120(a) and notice to officers | Stoner | Watlingten | Statutory language aligns with Arkansas precedent; a reasonable officer would know the statute requires a purpose to employ the weapon against a person |
Key Cases Cited
- Lambert v. City of Dumas, 187 F.3d 931 (8th Cir. 1999) (Fourth Amendment right not to be arrested without probable cause)
- Saucier v. Katz, 533 U.S. 194 (2001) (two-step qualified-immunity framework (later narrowed))
- Anderson v. Creighton, 483 U.S. 635 (1987) (objective reasonableness review for qualified immunity)
- Kuehl v. Burtis, 173 F.3d 646 (8th Cir. 1999) (clearly established-right standard for Fourth Amendment arrests)
- Garcia v. State, 969 S.W.2d 591 (Ark. 1998) (statutory element requiring a purpose to employ a weapon against a person)
- Nesdahl v. State, 890 S.W.2d 596 (Ark. 1995) (evidence supports conviction where weapon readily available with purpose to employ it)
- McGuire v. State, 580 S.W.2d 198 (Ark. 1979) (prior version of statute linked possession with purpose to employ as a weapon)
- Robinson v. United States, 670 F.3d 874 (8th Cir. 2012) (cites Arkansas practice of defining carrying with purpose to employ a weapon)