Coleman v. City of New York, 688 F. App'x 56

In Jan. 2009 Coleman was stopped by NYPD Officers Merendino and Lento; an exchange grew contentious and Coleman drove off abruptly when he believed the officer was delaying him.
Officers allege Coleman’s side mirror struck Merendino as he left; Coleman denies striking her. Officers pursued, Coleman stopped, a sergeant arrived, and Coleman was arrested.
Coleman was charged with multiple counts including two felony assault-in-the-second-degree counts (alleging the vehicle was a deadly instrument and victim was an officer), several misdemeanors, and traffic violations. He was released without bail after arraignment.
The prosecutor moved to dismiss the two felony assault counts months later; other non-traffic criminal counts were dismissed on speedy trial grounds; traffic counts were resolved by an ACD after two years.
Coleman sued under 42 U.S.C. § 1983 for malicious prosecution; the district court granted summary judgment to defendants on grounds of probable cause and lack of a constitutional seizure; on appeal this Court remanded limited to malicious prosecution for the assault charges because factual dispute existed about whether Coleman struck Merendino.
On remand the district court (after converting a motion in limine to summary judgment) ruled Coleman failed to prove a post-arraignment constitutional deprivation of liberty attributable to the assault charges and granted defendants summary judgment; this Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Coleman suffered a post-arraignment deprivation of liberty (constitutional "seizure") caused by the allegedly baseless assault charges	Coleman argued that repeated court appearances over two years after arraignment constituted a post-arraignment seizure supporting his § 1983 malicious prosecution claim	Defendants argued Coleman’s required court appearances and other burdens were not attributable to the assault counts because other charges (supported by probable cause) and traffic matters (ACD) would have produced the same obligations	Held for defendants: Coleman failed to show a post-arraignment deprivation of liberty that was caused by the assault prosecution, so § 1983 malicious prosecution claim fails; court did not reach favorable-termination issue

Young v. Cty. of Fulton, 160 F.3d 899 (2d Cir.) (summary-judgment review standard)
Boyd v. City of N.Y., 336 F.3d 72 (2d Cir. 2003) (state and federal malicious prosecution elements are substantially the same)
Manganiello v. City of N.Y., 612 F.3d 149 (2d Cir. 2010) (elements of malicious prosecution under New York law)
Albright v. Oliver, 510 U.S. 266 (U.S. 1994) (malicious prosecution under § 1983 grounded in the Fourth Amendment)
Singer v. Fulton County Sheriff, 63 F.3d 110 (2d Cir. 1995) (distinguishing false arrest and malicious prosecution; requirement of post-arraignment legal-process deprivation)
Rohman v. N.Y.C. Transit Auth., 215 F.3d 208 (2d Cir. 2000) (post-arraignment court-appearance burden can sometimes satisfy constitutional-deprivation element)