Hoyos v. City of New York, 650 F. App'x 801

Plaintiff Alberto Hoyos was prosecuted after a traffic stop; officers alleged he cut across lanes, appeared groggy with bloodshot eyes, and refused a breathalyzer.
Hoyos sued under 42 U.S.C. § 1983 for malicious prosecution and fabrication of evidence against the City of New York and two officers.
The district court granted summary judgment for defendants, concluding there was probable cause to prosecute and that any fabricated evidence did not proximately cause deprivation of liberty.
Hoyos filed a motion for reconsideration of the summary judgment; the district court denied it and he appealed only that denial (he had missed the deadline to appeal the underlying judgment directly).
On appeal, the Second Circuit reviewed only the denial of reconsideration and evaluated whether Hoyos showed an intervening change of law, new evidence, or clear error to justify reconsideration.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether probable cause is a complete defense to malicious prosecution when officers fabricated evidence	Hoyos: probable cause should not bar malicious prosecution if evidence was fabricated that influenced prosecution	Defendants: existence of probable cause defeats malicious prosecution claim	Court: No clear error—probable cause to prosecute is a complete defense; Ricciuti/Jocks addressed probable cause to arrest and do not create an exception here
Whether allegedly fabricated evidence proximately caused Hoyos’s deprivation of liberty (fabrication-of-evidence claim)	Hoyos: causation is proximate; fabricated evidence could have inflated the case and caused prosecutors to proceed when they otherwise might not have	Defendants: independent, ample probable cause supports prosecution; any fabricated evidence did not cause the deprivation beyond the prosecution itself	Court: Although proximate cause governs fabrication claims, no clear error in district court’s finding that independent, ample probable cause was strong enough that fabricated evidence did not proximately cause the liberty deprivations
Procedural: Whether denial of reconsideration was improper	Hoyos: motion warranted based on alleged errors in summary judgment analysis	Defendants: no new law/evidence and no manifest injustice; denial appropriate	Court: Affirmed denial—Hoyos did not show new law, new evidence, or clear error

Virgin Atl. Airways, Ltd. v. Nat’l Mediation Bd., 956 F.2d 1245 (2d Cir. 1992) (grounds for reconsideration defined)
Ricciuti v. N.Y.C. Transit Auth., 124 F.3d 123 (2d Cir. 1997) (addressed probable cause to arrest and manufactured evidence issue)
Jocks v. Tavernier, 316 F.3d 128 (2d Cir. 2003) (distinguished arrest probable cause from malicious prosecution claims)
Savino v. City of New York, 331 F.3d 63 (2d Cir. 2003) (probable cause is a defense to malicious prosecution in New York)
Stansbury v. Wertman, 721 F.3d 84 (2d Cir. 2013) (probable cause standard for prosecution is higher than for arrest)
Barnes v. Anderson, 202 F.3d 150 (2d Cir. 1999) (fabrication-of-evidence claims apply proximate causation principle)
Townes v. City of New York, 176 F.3d 138 (2d Cir. 1999) (fabrication claims analogized to state tort causation principles)