Heidi Hazelquist v. Stephan
695 F. App'x 341
| 9th Cir. | 2017Background
- Heidi Hazelquist, proceeding pro se, sued under 42 U.S.C. § 1983 and state law after an arrest and temporary involuntary commitment.
- Defendants included officers (Stephan, Klewin) and a commitment decisionmaker (Hull); district court granted summary judgment for all defendants.
- Hazelquist alleged unlawful seizure (false arrest), excessive force, malicious prosecution, involuntary commitment due process violation, and state claims (defamation, assault, false imprisonment).
- District court found no genuine disputes on probable cause for arrest, reasonable force, failure to comply with state tort-claim presentment rules for malicious prosecution, and that state claims were time-barred.
- Court also held Hull entitled to qualified immunity on the involuntary-commitment due-process claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Unlawful arrest / probable cause | Hazelquist: arrest lacked probable cause | Stephan: officers had reasonably trustworthy information supporting arrest | Summary judgment for Stephan; no genuine dispute that probable cause existed |
| Involuntary commitment / due process | Hazelquist: temporary commitment violated clearly established due-process rights | Hull: decision was lawful under state emergency detention scheme; qualified immunity applies | Qualified immunity for Hull; no clearly established due-process violation |
| Excessive force | Hazelquist: Klewin used objectively unreasonable force during restraint | Klewin: force was reasonable under circumstances (mental-health evaluation, control) | Summary judgment for Klewin; no genuine dispute force was reasonable |
| Malicious prosecution / tort notice | Hazelquist: prosecution was malicious | Stephan & Hull: plaintiff failed to file required state tort-claim notice and wait 60 days | Summary judgment for Stephan and Hull; failure to comply with statutory presentment requirement |
| State claims (defamation, assault, false imprisonment) | Hazelquist: asserted state-law torts | Defendants: claims barred by statute of limitations | Summary judgment for defendants; Hazelquist conceded claims were time-barred |
Key Cases Cited
- Ramirez v. City of Buena Park, 560 F.3d 1012 (9th Cir.) (probable cause standard for unlawful arrest)
- Lacey v. Maricopa County, 693 F.3d 896 (9th Cir.) (§ 1983 unlawful arrest requires absence of probable cause)
- Sjurset v. Button, 810 F.3d 609 (9th Cir.) (qualified immunity framework for government officials)
- Luchtel v. Hagemann, 623 F.3d 975 (9th Cir.) (objective-reasonableness standard for excessive-force claims)
- In re Detention of June Johnson, 322 P.3d 22 (Wash. Ct. App.) (Washington emergency detention scheme and procedural due process)