Garcia v. County of Merced
639 F.3d 1206
| 9th Cir. | 2011Background
- Garcia was arrested on suspicion of smuggling methamphetamine into the Merced County Jail via a reverse sting aided by jailhouse informant Plunkett and Garcia's client Robledo.
- Officers Cardwood and Taylor conducted corroboration of Plunkett's tips, confirmed Robledo’s incarceration, Garcia’s representation as Robledo's attorney, and related jail procedures.
- A Bag containing methamphetamine was delivered to Garcia, who accepted it at his office during surveillance, leading to a search warrant for Garcia's office executed under a master’s supervision.
- A district judge approved the informant-driven operation and the warrant; the search of Garcia’s office followed and evidence was seized, with prior district-attorney approval of the plan.
- Garcia was charged; the district court denied qualified immunity on some claims, and the Ninth Circuit reversed and remanded for judgment in favor of the Officers.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Probable cause to arrest Garcia | Garcia contends no probable cause existed. | Officers assert probable cause based on reverse sting and corroborated informant data. | Probable cause existed; reasonable officers could conclude Garcia engaged in smuggling. |
| Qualified immunity for arrest | Garcia argues officers violated rights; immunity not warranted. | Officers acted on reasonable beliefs; not clearly unlawful. | Officers entitled to qualified immunity for the arrest. |
| Search warrant probable cause / misrepresentation | Omission of Plunkett's record constitutes deception undermining probable cause. | Omissions were not material; informant credibility required corroboration; warrant would issue anyway. | No constitutional violation; warrant would have issued without the omitted information. |
| State law false imprisonment | False imprisonment claim survives if arrest lacked probable cause. | Arrest had probable cause; state law immunity applies. | District court erred; state-law false arrest resolved in favor of the Officers; qualified immunity covers the conduct. |
Key Cases Cited
- Beck v. Ohio, 379 U.S. 89 (1964) (probable cause standard for arrests)
- Lopez, 482 F.3d 1067 (9th Cir. 2007) (probable cause may be a fair probability, not certainty)
- Saucier v. Katz, 533 U.S. 194 (2001) (two-step qualified immunity framework)
- Anderson v. Creighton, 483 U.S. 635 (1987) (public officials not liable for reasonable but mistaken actions)
- Malley v. Briggs, 475 U.S. 335 (1986) (fear of liability should not chill reasonable official action)
- Gates v. Illinois, 462 U.S. 213 (1983) (probable cause in warrant applications; total circumstances test)
- Leon, 468 U.S. 897 (1984) (cooling-off rule for magistrates; good-faith exception context)
- Banks v. Dretke, 540 U.S. 668 (2004) (informant credibility defects require corroboration)
- On Lee v. United States, 343 U.S. 747 (1952) (informant testimony may be valuable despite risks)
- Kastigar v. United States, 406 U.S. 441 (1972) (immunity statutes support use of informant testimony)
- Cunningham v. Gates, 229 F.3d 1271 (9th Cir. 2000) (reasonable reliance when information is corroborated)
- United States v. Bernard, 623 F.2d 551 (9th Cir. 1980) (collective knowledge doctrine for probable cause)
- United States v. Stanert, 762 F.2d 775 (9th Cir. 1985) (standards for evaluating warrants and omissions)