Estella Medrano v. Robert Diventi
688 F. App'x 471
| 9th Cir. | 2017Background
- Medrano was arrested after an armed robbery; charges against her were later dismissed and she sued Phoenix police under 42 U.S.C. § 1983 for false imprisonment.
- Store surveillance video captured the robbery; parties dispute mainly the inferences drawn from the video (e.g., whether the female suspect was acting as an accomplice or distracted the clerk).
- Officers arrested Medrano based on her association with the male robber, her resemblance to the female suspect, and officer photo identification from a driver’s license photo.
- Medrano challenged the officers’ inferences (e.g., that she was with the robber, that she matched the suspect’s appearance) and argued those inferences were insufficient for probable cause.
- The district court granted summary judgment for defendants, finding probable cause and applying qualified immunity; Medrano appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether historical facts create a triable dispute on probable cause | Medrano: factual inferences are disputed and require a jury | Defendants: video and identification produce objective facts supporting probable cause | Court: facts not genuinely disputed for purposes of probable cause; summary judgment proper |
| Whether the officers’ inferences from the video were unreasonable | Medrano: alternative reasonable inferences exist (e.g., not accomplice) | Defendants: officers’ inferences were reasonable given the conduct and context | Court: existence of other inferences does not show officers’ inferences were unreasonable |
| Whether photo identification and physical resemblance were unreliable | Medrano: weight/appearance differences and claimed mistaken ID undercut probable cause | Defendants: no irregularities in photo ID; resemblance plus association supported arrest | Court: cumulative facts supported probable cause; reasonable officer could believe arrest lawful |
| Whether qualified immunity precludes liability | Medrano: officers not entitled to immunity because no probable cause | Defendants: officers entitled to immunity because law was not clearly violated and belief was reasonable | Court: affirmed summary judgment on qualified immunity grounds (probable cause objectively supported) |
Key Cases Cited
- Gordon v. Virtumundo, Inc., 575 F.3d 1040 (9th Cir.) (standard for affirming summary judgment)
- Sinaloa Lake Owners Ass’n v. City of Simi Valley, 70 F.3d 1095 (9th Cir.) (two-step qualified immunity framework)
- ActUp!/Portland v. Bagley, 988 F.2d 868 (9th Cir.) (probable cause objective-reasonableness is ordinarily a question for the court)
- Sams v. Yahoo! Inc., 713 F.3d 1175 (9th Cir.) (historical facts supporting objective reasonableness is a legal question)
- Torres v. City of Los Angeles, 548 F.3d 1197 (9th Cir.) (photo-identification/lineup issues can preclude probable cause where disputed)
- Wallace v. Kato, 549 U.S. 384 (U.S. Supreme Court) (false imprisonment ends when held pursuant to legal process)