Craig Geness v. Jason Cox
902 F.3d 344
| 3rd Cir. | 2018Background
- In 2006 Craig Geness, an intellectually disabled resident of an assisted‑living facility, was accused after an on‑the‑spot investigation by Detective Jason Cox of pushing another resident, Ronald Fiffik, whose later death led to homicide charges against Geness. Contemporaneous EMS and hospital records described an accidental fall.
- Cox conducted a one‑day investigation on November 16, 2006, obtained a confession from Geness, and swore an affidavit of probable cause; a magistrate issued a warrant. Cox later stated he had no recollection of seeing the EMS/hospital records before the lawsuit.
- Geness was detained and underwent delayed and repeated competency evaluations; psychiatrists found him incompetent to stand trial with a poor prognosis for restoration. Over ~9 years he moved between jail, psychiatric facilities, and civil commitment without a timely habeas hearing or trial.
- In 2015 the Commonwealth entered a nolle prosequi because it believed it could not meet its burden of proof (and Geness remained incompetent). The state court dismissed charges without prejudice and Geness was released in December 2015.
- In 2016 Geness sued Cox and others under 42 U.S.C. § 1983 (false arrest, false imprisonment, malicious prosecution, reckless investigation), plus due process and ADA claims. The district court dismissed most § 1983 claims as time‑barred or unsupported by evidence, dismissed malicious prosecution for lack of favorable termination, and denied leave to amend to sue the Commonwealth on ADA/due process grounds.
- The Third Circuit affirmed dismissal of the § 1983 claims (statute of limitations and lack of triable dispute as to probable cause), reversed denial of leave to amend, and remanded to allow Geness to reinstate ADA and due process claims against the Commonwealth.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether false arrest/false imprisonment/reckless‑investigation § 1983 claims were timely | Geness argued tolling/equitable doctrines and that his attorney delays preserved claims | Cox argued claims accrued when bound over for trial (2007) and thus expired under the two‑year statute of limitations | Court: Claims were time‑barred; Geness waived tolling arguments on appeal and limitations accrued at commitment/bound‑over stage |
| Whether the nolle prosequi constituted "favorable termination" for malicious prosecution | Geness argued the DA’s stated evidentiary insufficiency and nol pros show favorable termination | Cox argued the order’s language (dismissed without prejudice) did not indicate innocence | Court: Nol pros coupled with prosecutor’s reasons and record evidence satisfied favorable termination; district court erred to the contrary |
| Whether probable cause existed such that malicious prosecution (and related) claims fail | Geness argued Cox omitted/excluded exculpatory EMS/hospital records and failed to account for Geness’s incompetence/coercion in confession | Cox relied on affidavit asserting he lacked recollection of seeing the records, that he properly obtained a Miranda waiver and confession, and that information known to him (witness statements, confession) supported probable cause | Held: Even if omissions would be material, plaintiff failed to adduce admissible evidence (no depositions, no affidavits from witnesses or experts) to create a genuine dispute; summary judgment for Cox affirmed on probable cause grounds |
| Whether the district court properly denied leave to amend to add the Commonwealth for ADA and due process claims (Rooker‑Feldman, futility, undue delay) | Geness sought to add Commonwealth, alleging prolonged detention/commitment violated ADA and due process | District court found amendment futile (Rooker‑Feldman) and delayed | Held: Denial was error. Rooker‑Feldman inapplicable because claims arise independently from state‑court rulings; amendment was not futile on other grounds and delay was not undue; remand to permit claims against the Commonwealth |
Key Cases Cited
- Manuel v. City of Joliet, Ill., 137 S. Ct. 911 (2017) (Fourth Amendment governs claims for unlawful pretrial detention)
- Wallace v. Kato, 549 U.S. 384 (2007) (accrual rule for claims sounding in false arrest/imprisonment)
- Ashcroft v. Al‑Kidd, 563 U.S. 731 (2011) (qualified immunity and clearly established law inquiry)
- Jackson v. Indiana, 406 U.S. 715 (1972) (indefinite commitment solely for incompetency violates due process)
- Donahue v. Gavin, 280 F.3d 371 (3d Cir. 2002) (nol pros may establish favorable termination depending on circumstances)
- Kossler v. Crisanti, 564 F.3d 181 (3d Cir. 2009) (fact‑based inquiry into whether termination indicates innocence)
- Dempsey v. Bucknell Univ., 834 F.3d 457 (3d Cir. 2016) (reckless omissions in warrant affidavits and materiality standard)
- Wilson v. Russo, 212 F.3d 781 (3d Cir. 2000) (standards for false statements/omissions in warrant affidavits)
- Foman v. Davis, 371 U.S. 178 (1962) (standards for leave to amend complaints)
- Zimmerman v. Corbett, 873 F.3d 414 (3d Cir. 2017) (elements of malicious prosecution under § 1983)