Daryl Sampson v. Village of Mackinaw City
685 F. App'x 407
| 6th Cir. | 2017Background
- On March 13, 2013 Officer Klave, working from task-force information, conducted a planned traffic stop of a white Dodge Intrepid after a CI reported that suspected drug-dealer Darryl Duncan would be meeting the CI and had heroin.
- Sampson had driven Duncan from Detroit, waited in the car at a hotel at ~3:00 a.m., then followed the CI; Klave stopped the car, arrested Duncan on an outstanding warrant, and obtained Sampson’s consent to search the vehicle.
- Two small baggies of heroin were found in the back seat; Duncan later claimed ownership but the bags were stowed in Sampson’s vehicle (owned by Sampson).
- Officer Klave prepared an affidavit relying on the CI and his own observations; the prosecutor authorized arrest warrants and Sampson was arraigned. At the preliminary exam the court bound Duncan over but dismissed charges against Sampson for lack of proof he knew of the heroin.
- Sampson sued under 42 U.S.C. § 1983 for illegal stop, false arrest, and malicious prosecution, and sued the village under Monell for failure to train/supervise; the district court granted summary judgment to defendants and declined supplemental jurisdiction over state-law claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Legality of traffic stop (reasonable suspicion) | Stop unlawful because Sampson did not run a stop sign | Klave had reasonable suspicion from CI tip, corroboration, time/place, and observations | Stop was supported by reasonable suspicion; affirmed |
| False arrest / probable cause | No probable cause; state court dismissal shows lack of probable cause | Even if mistaken, Klave reasonably believed probable cause existed; qualified immunity applies | Qualified immunity: Klave’s belief was reasonable; summary judgment for defendants |
| Malicious prosecution | Prosecutor had no probable cause; Klave’s report led to prosecution | Klave provided truthful information; omissions were immaterial or negligent, not blameworthy participation | No liability: Klave didn’t knowingly cause prosecution; summary judgment for defendants |
| Municipal liability (Monell) | Village deliberately indifferent by not performing formal officer evaluations | No evidence that lack of evaluations was a policy/custom, caused injury, or showed deliberate indifference | No Monell evidence; summary judgment for Village |
Key Cases Cited
- Voyticky v. Village of Timberlake, 412 F.3d 669 (6th Cir.) (defining probable-cause requirement for § 1983 false-arrest claims)
- Ahlers v. Schebil, 188 F.3d 365 (6th Cir.) (officers must not ignore clearly exculpatory evidence when asserting probable cause)
- Maryland v. Pringle, 540 U.S. 366 (U.S.) (officer may infer common enterprise among vehicle occupants for possession)
- United States v. Di Re, 332 U.S. 581 (U.S.) (informant singling out one passenger can defeat probable cause for others)
- White v. Pauly, 580 U.S. --- (U.S.) (clearly established law must be particularized; prevents generalized qualified-immunity failures)
- Hunter v. Bryant, 502 U.S. 224 (U.S.) (qualified immunity shields reasonable, even mistaken, judgments)
- Sykes v. Anderson, 625 F.3d 294 (6th Cir.) (elements of § 1983 malicious-prosecution claim)
- City of Canton v. Harris, 489 U.S. 378 (U.S.) (Monell deliberate-indifference standard for failure-to-train claims)