George Lopez Ramirez v. City of Glendale
21-55036
| 9th Cir. | Mar 10, 2022Background
- Plaintiff George Lopez Ramirez sued the City of Glendale and officers (including Aaron Zeigler) under 42 U.S.C. § 1983 for false arrest (Fourth Amendment) and unlawful imprisonment (Fourteenth Amendment).
- District court granted summary judgment for defendants; plaintiff appealed challenging factual resolution on probable cause and post‑arrest detention.
- Witness Medina reported a man was "pushing" her; plaintiff admitted to Officer Zeigler that he was in a dating relationship with Medina and had "grabbed" her arms.
- Zeigler arrested plaintiff for domestic battery and also for an outstanding warrant; plaintiff did not dispute those two factual assertions used by the officer.
- The panel reviewed summary judgment de novo and applied the objective probable‑cause standard for arrests.
- The court concluded that the undisputed facts established probable cause for domestic battery and that probable cause defeats the § 1983 unlawful‑imprisonment claim, and affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Probable cause for arrest (Fourth Amendment) | District court improperly resolved material fact disputes; no probable cause | Zeigler had probable cause based on Medina's report and plaintiff's admission he grabbed her; objective inquiry controls | Court: Probable cause existed; summary judgment affirmed |
| Post‑arrest detention (Fourteenth Amendment unlawful imprisonment) | Detention on a mistaken warrant/after arrest violated due process; further investigation was warranted | Probable cause for domestic battery (and warrant) defeats unlawful‑imprisonment claim | Court: No Fourteenth Amendment violation as a matter of law; claim fails |
Key Cases Cited
- Phattey, 943 F.3d 1277 (9th Cir.) (standard of review for summary judgment)
- Reed v. Lieurance, 863 F.3d 1196 (9th Cir.) (defines probable‑cause objective standard)
- Rosenbaum v. Washoe County, 663 F.3d 1071 (9th Cir.) (probable‑cause framework)
- United States v. Struckman, 603 F.3d 731 (9th Cir.) (officer's subjective intent immaterial)
- United States v. Magallon‑Lopez, 817 F.3d 671 (9th Cir.) (arrest lawful if facts support probable cause for any offense)
- Garcia v. County of Riverside, 817 F.3d 635 (9th Cir.) (detention on mistaken warrant may violate due process when further investigation was required)
- Cabrera v. City of Huntington Park, 159 F.3d 374 (9th Cir.) (probable cause defeats § 1983 false‑arrest/imprisonment claim)