Jeffries v. Las Vegas Metropolitan Police Department, 713 F. App'x 549

Jeffries appeals the district court’s grant of summary judgment to the Las Vegas Metropolitan Police Department on his 42 U.S.C. § 1983 claims.
The panel reviews the district court’s decision de novo and affirms summary judgment in favor of the Department.
The district court admitted seven exhibits with authentication issues; Owens authenticated Exhibits A and C, and Exhibit F was verified by Jeffries.
Exhibits D, E, and G were unauthenticated, but their consideration was harmless error because a competent witness could authenticate them at trial.
Jeffries alleged violations under the Fourth, Fifth, and Fourteenth Amendments related to probationary employment and a home entry following a 911 call.
The court held the Department’s actions were constitutional and followed due process procedures, affirming dismissal of all § 1983 claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court properly admitted and considered exhibits	Jeffries challenged authentication of some exhibits	Exhibits were admissible as they could be authenticated at trial or were harmless error	Exhibits properly considered; some unauthenticated exhibits treated as harmless error
Whether the Fourth Amendment was violated by the home entry	Entry without proper justification violated the Fourth Amendment	Entry was justified by exigent circumstances under the domestic violence context	No Fourth Amendment violation; exigent circumstances supported entry
Whether the Fifth Amendment self-incrimination right was implicated	Statements or compelled testimony could implicate self-incrimination	No compelled questioning or use in a criminal case occurred	No Fifth Amendment violation; right not implicated
Whether due process protections were violated in the probationary employment context	Procedural due process requirements were not satisfied	Due process was provided via notice and an informal hearing	Due process satisfied; summary judgment affirmed

Fraser v. Goodale, 342 F.3d 1032 (9th Cir. 2003) (admissibility of evidence on summary judgment)
Hal Roach Studios, Inc. v. Feiner & Co., 896 F.2d 1542 (9th Cir. 1990) (harmless error for unauthenticated evidence)
Karim-Panahi v. L. A. Police Dep’t, 839 F.2d 621 (9th Cir. 1988) (elements of a § 1983 claim)
United States v. Martinez, 406 F.3d 1160 (9th Cir. 2005) (domestic violence exigency doctrine justifies entry)
Chavez v. Martinez, 538 U.S. 760 (2003) (Self-Incrimination Clause not violated unless used in criminal case)
Bd. of Regents of State Colleges v. Roth, 408 U.S. 564 (1972) (procedural due process applies to liberty/property deprivations)
Weiner v. San Diego Cty., 210 F.3d 1025 (9th Cir. 2000) (de novo review of summary judgment)