Freedom Pfaendler v. Sahuarita, Town Of, 23-15412

Freedom Christopher Austin Pfaendler was arrested at a store in Sahuarita, Arizona, after allegedly failing to leave when requested by a manager.
Pfaendler brought claims under 42 U.S.C. § 1983 and Arizona state law for false arrest, malicious prosecution, and illegal search against the Town of Sahuarita and the officers involved.
The district court granted summary judgment to the defendants, finding probable cause existed for the arrest and that the officers’ actions were constitutionally valid or protected by qualified immunity.
On appeal, Pfaendler contended that material factual disputes remained and challenged the court’s application of the summary judgment standard regarding probable cause.
The appellate court reviewed the case de novo and examined whether the facts supported the grant of summary judgment on all claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Probable cause for arrest	No probable cause; factual disputes exist	Probable cause existed based on manager's requests and officers’ observations	Court found probable cause was present; summary judgment affirmed
Reliance on exculpatory evidence	Officers ignored evidence suggesting lack of knowing refusal	Officers considered all evidence; fair probability standard applies	Court held officers reasonably found fair probability Pfaendler knowingly stayed
Subjective motivation for arrest	Arrest was based on "contempt of cop" (retaliatory animus)	Motivations irrelevant if objective facts support arrest	Court held objective facts control; subjective intent irrelevant
Illegal search and equitable relief	Should be reinstated because arrest lacked probable cause	No basis since arrest was supported by probable cause	Court rejected; absence of probable cause argument fails

O’Doan v. Sanford, 991 F.3d 1027 (9th Cir. 2021) (summary judgment de novo standard and objective reasonableness of police conduct as a question of law)
Yousefian v. City of Glendale, 779 F.3d 1010 (9th Cir. 2015) (absence of probable cause required for false arrest/malicious prosecution)
Slade v. City of Phoenix, 541 P.2d 550 (Ariz. 1975) (probable cause standard under Arizona law)
District of Columbia v. Wesby, 583 U.S. 48 (2018) (probable cause based on totality of circumstances)
Lassiter v. City of Bremerton, 556 F.3d 1049 (9th Cir. 2009) (definition of probable cause)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (summary judgment and material factual disputes)
McLaughlin v. Liu, 849 F.2d 1205 (9th Cir. 1988) (unreasonable inferences from circumstantial evidence)
Whren v. United States, 517 U.S. 806 (1996) (irrelevance of officer's subjective intent in Fourth Amendment analysis)
Nieves v. Bartlett, 139 S. Ct. 1715 (2019) (probable cause defeats claims based on retaliatory arrest)