Daniel Bradley v. Blake Kuntz, 655 F. App'x 56

Background

Pro se plaintiff Daniel Bradley sued Officer Blake Kuntz and the City of Bethlehem under 42 U.S.C. § 1983 after being arrested and jailed 102 days for an alleged theft he says he did not commit.
The victim, Rosemary Johnson, directly identified Bradley as the sole person with access when $150 went missing; Kuntz knew Johnson and found her on-the-record statements clear and specific.
Kuntz obtained an arrest warrant based on his investigation and Johnson’s testimony; at the preliminary hearing Johnson’s unlawful-taking allegation was bound over for trial.
After the preliminary hearing an ADA notified Kuntz that Bradley had documentation showing Bradley was in a mental-health facility on the date of the alleged theft — information Kuntz did not have when he sought the warrant.
Bradley alleged Fourth, Fifth, and Fourteenth Amendment claims (illegal seizure, deprivation of liberty/due process), state-law false arrest/false imprisonment and malicious prosecution, and a municipal failure-to-train claim against the City.
The district court granted summary judgment for defendants on all claims; the Third Circuit summarily affirmed, concluding no substantial question on appeal.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Malicious prosecution (Fourth & PA law): whether prosecution proceeded without probable cause and with malice	Bradley: no probable cause existed because he was innocent and later produced evidence placing him in a facility on the offense date	Kuntz: had probable cause based on victim’s credible, specific account and his investigation; no evidence of malice	Held: probable cause existed; no evidence of malice; summary judgment for defendants
False arrest / false imprisonment: whether arrest pursuant to warrant was invalid due to officer’s alleged omissions	Bradley: Kuntz omitted material exculpatory facts (hospitalization) when applying for warrant	Kuntz: did not know of hospital evidence when applying; conducted a good-faith investigation; no deliberate or reckless omissions	Held: Bradley failed to show Kuntz knowingly/recklessly made material false statements or omissions; summary judgment for defendants
Fourth/Fourteenth Amendment substantive due process / deprivation of liberty	Bradley: constitutional deprivations beyond false arrest/ prosecution	Defendants: Fourth Amendment governs seizure-based claims; Fourteenth claim duplicative	Held: Fourth Amendment controls; substantive due process claim duplicative and properly dismissed
Failure-to-train municipal liability (Monell theory)	Bradley: City failed to train Kuntz, causing constitutional injury	City: no evidence of deliberate indifference or specific training deficiency causally linked to injury	Held: Bradley failed to identify specific training deficiency or deliberate indifference; summary judgment for City

Key Cases Cited

Johnson v. Knorr, 477 F.3d 75 (3d Cir. 2007) (elements of malicious prosecution under the Fourth Amendment)
Maryland v. Pringle, 540 U.S. 366 (2003) (probable cause is reasonable ground for belief of guilt)
Groman v. Twp. of Manalapan, 47 F.3d 628 (3d Cir. 1995) (probable cause, not actual guilt, controls § 1983 false-arrest claims)
Wilson v. Russo, 212 F.3d 781 (3d Cir. 2000) (officer liability for warrant-based arrests when officer knowingly or recklessly makes false statements or omissions)
Albright v. Oliver, 510 U.S. 266 (1994) (use specific constitutional amendment rather than generalized substantive-due-process analysis)
City of Canton v. Harris, 489 U.S. 378 (1989) (failure-to-train liability requires deliberate indifference and causal nexus)
Reitz v. County of Bucks, 125 F.3d 139 (3d Cir. 1997) (difficulty of proving failure-to-train; must show specific deficiency and causal link)
Baker v. McCollan, 443 U.S. 137 (1979) (arrest based on probable cause cannot be source of false-imprisonment claim)
Barna v. City of Perth Amboy, 42 F.3d 809 (3d Cir. 1994) (Fourth Amendment standards govern seizure-based claims)