Gordon Goines v. Valley Community Services Board
2016 U.S. App. LEXIS 8512
| 4th Cir. | 2016Background
- Goines, who has cerebellar ataxia (physical/speech impairments but no cognitive or mental-health diagnosis), went to report cable theft; he asked police not to confront a neighbor.
- Officers Shaw and Dean took Goines from the station to his apartment, did not turn on the TV (so did not hear the line noise), handcuffed him, and transported him to a medical facility for involuntary mental-health evaluation.
- At the hospital, evaluator Jenna Rhodes completed a Preadmission Screening Report (attached to the complaint) which, based on her observations and information from officers, concluded Goines had a mental illness and posed a danger; a magistrate issued a temporary detention order and Goines was detained for six days.
- Goines sued under 42 U.S.C. § 1983 alleging unlawful seizure (Fourth Amendment) and lack of probable cause; defendants moved to dismiss under Rule 12(b)(6). The district court treated two police Incident Report statements as true and dismissed all claims; it also accepted the Screening Report and dismissed Rhodes and her employer.
- The Fourth Circuit affirmed dismissal as to Rhodes, her employer (Valley Community Services Board), and Officer Williams, but vacated and remanded the dismissal as to Officers Shaw and Dean, finding Goines’ complaint—viewed without crediting the officers’ written Incident Report as true—adequately alleged lack of probable cause and denial of qualified immunity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court properly treated factual statements in officers’ Incident Report as true at the 12(b)(6) stage | Goines: He quoted parts of the Incident Report to show officers’ misperception, not to adopt its facts as true | Defendants: Incident Report was integral/authentic and its content should control over conflicting complaint allegations | Court: Error to treat unilateral, self‑serving Incident Report statements as true when plaintiff did not adopt them; the Report should be read as alleging the officers said those things, not as true facts |
| Whether Officers Shaw and Dean had probable cause/are entitled to qualified immunity for emergency mental‑health detention | Goines: Complaint alleges no signs of mental illness or threats; facts alleged (TV noise caused by spliced cable; officers didn’t turn on TV) do not support probable cause | Officers: Their reports/observations (as in Incident Report) justified reasonable belief of mental illness and danger, so qualified immunity applies | Court: Viewing complaint allegations as true (and not crediting officers’ Report), plaintiff plausibly alleged no probable cause; qualified immunity denied at dismissal stage; remand for further proceedings |
| Whether evaluator Rhodes and her employer are liable for wrongful detention | Goines: Screening Report did not supply sufficient information for probable cause; Rhodes lacked qualifications to diagnose psychotic disorder, so detention unlawful | Rhodes/Board: Screening Report contained evaluator’s observations and officer reports that provided reasonably trustworthy information establishing probable cause; Rhodes was an authorized designee under Virginia law | Court: Because Goines relied on and accepted the Screening Report for these claims, the Report's contents control and do establish probable cause; dismissal of Rhodes and the Board affirmed |
Key Cases Cited
- Harlow v. Fitzgerald, 457 U.S. 800 (qualified immunity standard)
- Bailey v. Kennedy, 349 F.3d 731 (4th Cir.) (probable‑cause requirement for mental‑health seizures)
- Cloaninger ex rel. Estate of Cloaninger v. McDevitt, 555 F.3d 324 (4th Cir.) (probable‑cause standard for psychological detention)
- Saucier v. Katz, 533 U.S. 194 (qualified immunity: whether unlawfulness would be apparent to reasonable officer)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (Rule 12(b)(6) pleading standard)