Claborn v. Yuma County
1 CA-CV 16-0204
| Ariz. Ct. App. | Mar 30, 2017Background
- Wife (MC) reported to Deputy Jaimez that appellant David Claborn removed community property in violation of a court-issued preliminary injunction in a pending divorce (injunction forbade transferring, concealing, selling, or otherwise disposing of community property).
- Jaimez investigated (interviewed MC, photographed missing items) and issued an "attempt to locate pending arrest" for interfering with judicial proceedings; items reported missing included dirt bikes, rifles, decorative items, and changed locks on a shared storage unit.
- Claborn voluntarily appeared at the sheriff’s office; Deputy Molina confirmed the injunction and arrested Claborn without incident. Claborn was held overnight; prosecutors issued a provisional declination citing insufficient evidence and the civil nature of the dispute.
- Claborn sued under 42 U.S.C. § 1983 and state-law claims (false imprisonment, negligence). The superior court dismissed some defendants and initially allowed state claims to proceed but later granted summary judgment for the deputies and Yuma County.
- On appeal, the court reviewed summary judgment de novo, affirmed dismissal of the § 1983 municipal claims for lack of policy/custom evidence, and affirmed summary judgment for the deputies on state-law false imprisonment and negligence because probable cause existed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Yuma County is liable under § 1983 via a policy, custom, or widespread practice | Claborn: County custom restricting overtime caused incomplete investigation (no interview), producing constitutional violations | County: No evidence of a policy or custom causing a constitutional violation; investigation continued and overtime restraint was not cited as the reason | Court: Affirmed summary judgment for County; plaintiff failed to show a policy/custom causing violation |
| Whether deputies had probable cause to arrest for interfering with judicial proceedings (violating injunction) | Claborn: Deputies lacked sufficient investigation to determine whether removed items were "necessities of life" exempt from injunction | Deputies: MC’s report, Jaimez’s investigation/photos, and Claborn’s admissions supplied reasonably trustworthy facts supporting probable cause | Court: Deputies had probable cause; summary judgment for deputies affirmed |
| Whether Molina needed an independent investigation before arresting Claborn | Claborn: Molina should have independently verified facts (e.g., interviewed Claborn) | Molina: Properly relied on Jaimez’s investigation and morning briefing; no duty to duplicate investigation | Court: No independent investigation required; reliance was reasonable |
| Whether conflicting testimony or later expert opinion creates a triable issue on probable cause | Claborn: Testimony/expert said they would have interviewed Claborn first, undermining probable cause | Deputies: Probable cause is an objective, time-of-arrest standard; other officers’ hindsight opinions irrelevant | Court: Hindsight/opinion does not defeat probable cause; summary judgment stands |
Key Cases Cited
- Monell v. Dep’t of Soc. Servs. of City of N.Y., 436 U.S. 658 (1978) (municipal liability requires a policy, custom, or practice causing the constitutional violation)
- Beck v. State of Ohio, 379 U.S. 89 (1964) (probable cause at the moment of arrest governs warrantless-arrest validity)
- Hunter v. Bryant, 502 U.S. 224 (1991) (probable cause is assessed objectively at the time of arrest; hindsight is irrelevant)
- Cameron v. Craig, 713 F.3d 1012 (9th Cir. 2013) (once probable cause exists, officer need not continue investigating to find exculpatory evidence)
- Stearns v. Clarkson, 615 F.3d 1278 (10th Cir. 2010) (officer may rely on another officer’s investigation when making an arrest)
- Lacy v. County of Maricopa, 631 F. Supp. 2d 1183 (D. Ariz. 2008) (probable cause need not exist for each individual alleged offense to justify arrest)
- First Am. Title Ins. Co. v. Johnson Bank, 239 Ariz. 348 (2016) (standard of review for summary judgment)
- S & S Paving & Const., Inc. v. Berkley Reg’l Ins. Co., 239 Ariz. 512 (2016) (appellate affirmance permissible if correct for any reason)
- Torrez v. Knowlton, 205 Ariz. 550 (App. 2003) (summary judgment standard)
- Hansen v. Garcia, Cletcher, Lund & McVean, 148 Ariz. 205 (App. 1985) (definition of probable cause in Arizona)