Cynthia Clayborn v. Dennis Struebling, 2013 U.S. App. LEXIS 20867

Cynthia Shelton Clayborn was arrested at Chesterfield Mall after mall employees reported a counterfeit $100 bill had been passed at a food-court restaurant.
Mall security and two restaurant employees identified Clayborn as the person who passed the bill; Clayborn denied it and gave inconsistent statements about what cash she used.
Clayborn found a receipt in a trash can showing a $13 transaction; a restaurant employee said that receipt was for a later purchase by someone else in Clayborn’s group and that the counterfeit pass occurred about 30 minutes earlier.
Officers arrested Clayborn, charged her with forgery, and she was later indicted; the prosecution dropped the charges before trial.
Clayborn sued the officers under 42 U.S.C. § 1983, claiming arrest without probable cause and insufficient investigation; the district court granted summary judgment to the officers on the merits and on qualified immunity.
The Eighth Circuit affirmed, concluding officers had arguable probable cause and were entitled to qualified immunity.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Probable cause for arrest	Clayborn: officers failed to conduct a "minimal further investigation" after finding the receipt and thus lacked probable cause.	Officers: two eyewitness IDs and Clayborn’s inconsistent statements provided probable cause; no duty to continue investigating.	Held: Officers had (arguable) probable cause; Kuehl distinguishes this case because officers did not ignore plainly exculpatory evidence.
Qualified immunity	Clayborn: officers acted unreasonably and violated clearly established Fourth Amendment rights.	Officers: even if mistaken, their actions were objectively reasonable under the totality of circumstances and fall within qualified immunity.	Held: Qualified immunity applies; conduct did not show plain incompetence or knowing law violation.

Kuehl v. Burtis, 173 F.3d 646 (8th Cir. 1999) (minimal further investigation could show absence of probable cause when exculpatory evidence was ignored)
Amrine v. Brooks, 522 F.3d 823 (8th Cir. 2008) (probable cause is assessed at the moment of arrest; later facts are irrelevant)
Borgman v. Kedley, 646 F.3d 518 (8th Cir. 2011) (qualified immunity applies if there is arguable probable cause)
Keil v. Triveline, 661 F.3d 981 (8th Cir. 2011) (two-part qualified-immunity test and objective-reasonableness standard)
Malley v. Briggs, 475 U.S. 335 (1986) (qualified immunity shields all but the plainly incompetent or those who knowingly violate the law)
Harlow v. Fitzgerald, 457 U.S. 800 (1982) (officials are protected unless they violated clearly established statutory or constitutional rights)