Crawford v. Geiger, 996 F. Supp. 2d 603

Nighttime encounter at a family business after 911 calls; Crawford and Reed armed, Ornelas unaware of the call; Geiger confronted them, ordering them to ground despite not identifying himself; multiple officers arrive with weapons drawn; Crawford disarmed and restrained; Hart, Evilsizer, Gatchel, Edelbrock, Lee and others arrest and detain the plaintiffs for hours; plaintiffs sue for §1983 rights and state torts, plus supervisory/derivative liability; the court grants in part and denies in part based on Iqbal/Twombly and qualified immunity; claims stream through Counts I–VIII with various prejudice/without prejudice dispositions; the court indicates discovery may allow amendment for some dismissed-without-prejudice claims; Monell and supervisory-liability theories are limited by the pleading and evidence presented; the case proceeds on surviving counts while certain claims are dismissed with prejudice for some defendants and without prejudice for others.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether claims survive under Iqbal/Twombly against on-scene officers	Plaintiffs allege detailed conduct and omissions; discovery may fill gaps	Many gaps are too sparse to plausibly plead	Some claims dismissed without prejudice; others may proceed after discovery
Whether supervisory and Monell claims survive	Entities failed to train/supervise adequately	Plaintiffs fail to allege specific policies; claims insufficient	Monell claim dismissed without prejudice; failure-to-train against supervisors dismissed without prejudice
Whether Count II (failure to intervene) survives	On-scene officers could have prevented harm by intervening	Insufficient non-conclusory facts	Count II dismissed without prejudice
Whether Count IV (First Amendment right to film) survives	There is a First Amendment right to film police; right clearly established	Qualified immunity may apply; rights not clearly established in circuit at that time	Count IV survives; right to film recognized and clearly established as of 2012; not barred by qualified immunity
Whether Count V (civil conspiracy) survives	Conspiracy pled with circumstantial, non-conclusory facts	Conspiracy pled with vague, conclusory allegations	Count V dismissed without prejudice

Saucier v. Katz, 533 U.S. 194 (2001) (two-step qualified immunity framework; later receded in part but cited for standards)
Anderson v. Creighton, 483 U.S. 635 (1987) (clearly established standard; right must be apparent in light of pre-existing law)
Monell v. Dep't of Social Services, 436 U.S. 658 (1978) (municipal liability requires policy/custom and causation)
Graham v. Connor, 490 U.S. 386 (1989) (reasonableness of force factors; totality of circumstances)
Glik v. Cunniffe, 655 F.3d 78 (2011) (First Amendment right to film police in public was clearly established; circuit analyses cited)