Janice Brown v. Andrew Knapp, 75 F.4th 638

Janice Brown traveled from Arkansas to Michigan to attend a hearing in her son Dale Reed Jr.’s homicide case; prosecutors had subpoenaed witness Sheneen Jones, who did not testify.
On September 14, 2018, an assistant prosecutor reported seeing Brown allegedly intimidate Jones at the courthouse and told officers there was probable cause to arrest Brown for witness intimidation.
MSP officers Willoughby and Knapp physically arrested Brown, who was booked and held in jail for ~96 hours; no probable-cause hearing or warrant was obtained during that time.
Detectives Dhooghe and possibly Shingleton were involved in the investigation and may have directed or participated in the arrest; the parties dispute Shingleton’s presence at the arrest.
Brown sued under 42 U.S.C. § 1983 for false arrest (Fourth Amendment) and for detention without a prompt probable-cause determination (Riverside claim). The district court denied qualified immunity; the Sixth Circuit affirmed denial on the Riverside claim and reversed on false-arrest.

Issue	Plaintiff's Argument	Defendant's Argument	Held
1) False arrest — was there probable cause to arrest Brown for witness intimidation?	Hanson’s eyewitness account was unreliable; Brown denies intimidating Jones.	Officers had reasonably trustworthy information (prosecutor’s eyewitness statement, prior contacts) that established probable cause.	No Fourth Amendment violation; probable cause existed. Qualified immunity granted to officers on false-arrest claim.
2) Prolonged detention — was detention >48 hours without probable-cause hearing a Riverside violation?	Brown: held ~96 hours without a prompt judicial determination; no extraordinary circumstances excused delay.	Defendants: they personally did not intentionally cause the delay and reasonably relied on other actors (prosecutor, jail, county).	Yes — officers violated Riverside; detention without prompt hearing violated Fourth Amendment. Qualified immunity denied for Riverside claim.
3) Which officers bore responsibility for securing the probable-cause hearing?	Brown: arresting officers (Willoughby, Knapp, and detectives who directed arrest) had duty under Michigan law to ensure prompt hearing.	Defendants: some detectives lacked authority or information to convene hearing; responsibility belonged to prosecutor/county.	Under Michigan law, arresting officers (including those who directed the arrest) had a duty to secure a prompt hearing; all four MSP defendants had Riverside obligations and cannot shift responsibility.

County of Riverside v. McLaughlin, 500 U.S. 44 (prompt probable-cause hearing within 48 hours required)
Devenpeck v. Alford, 543 U.S. 146 (probable cause assessed from facts known to arresting officer)
Ahlers v. Schebil, 188 F.3d 365 (eyewitness ID can supply probable cause absent reasons to doubt accuracy)
Cherrington v. Skeeter, 344 F.3d 631 (qualified immunity denied where >48-hour delay without extraordinary circumstances)
Drogosch v. Metcalf, 557 F.3d 372 (arresting officers must attempt to secure prompt probable-cause hearing under state law)
Rayfield v. City of Grand Rapids, [citation="768 F. App'x 495"] (distinguishable; qualified immunity granted where custody transfer between municipalities raised distinct questions)
Kelly v. Borough of Carlisle, 622 F.3d 248 (officer may rely on prosecutor’s legal opinion only if such reliance is objectively reasonable)
Ouza v. City of Dearborn Heights, 969 F.3d 265 (probable-cause analysis must consider totality of circumstances and exculpatory evidence)