Fox v. Rice, 2011 Ind. App. LEXIS 238

Fox sued West Central Community Corrections (WCCC) and Dennis Rice for false arrest, false imprisonment, and constitutional rights violations under Indiana and federal law.
The trial court granted summary judgment for WCCC, which Fox challenged on appeal and on rehearing.
The court previously held that an arrest warrant ended Fox's false imprisonment, citing Wallace v. Kato and Johnson v. Blackwell.
Fox argued Malley v. Briggs would preclude ending false imprisonment via an arrest warrant or that the warrant did not extinguish all wrongful conduct.
Willis, an employee of WCCC, sought the arrest warrant and allegedly acted without final policymaking authority.
On rehearing, the court clarified that Willis lacked final policymaking authority and that improper actions by a prosecutor can end a false imprisonment claim, with the redress split between officer and prosecutor.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does an arrest warrant end false imprisonment	Fox argues Malley shows warrant does not end false imprisonment.	Rice/WCCC contends warrant ends false imprisonment consistent with Wallace and Johnson.	Yes; arrest warrant ends false imprisonment; exceptions apply separably.
Was Willis the final policymaker for WCCC	Fox argues Willis acted without final policymaking authority.	Defendant argues Willis had final authority or delegated authority via director.	Willis lacked final policymaking authority; directive authority did not exist.

Malley v. Briggs, 475 U.S. 335 (1986) (arrest warrant with probable cause; not absolute immunity for prosecutorial actions)
Wallace v. Kato, 549 U.S. 384 (2007) (false imprisonment ends when legal process is initiated)
Johnson v. Blackwell, 885 N.E.2d 25 (Ind.Ct.App.2008) (timeliness of false imprisonment/false arrest claims)
Gernetzke v. Kenosha Unified Sch. Dist. No. 1, 274 F.3d 464 (7th Cir.2001) (definition of final policymaking authority)