Jennings v. Patton, 635 F.3d 655

Judge Patton, a Mississippi county judge, allegedly caused Jennings to be prosecuted without probable cause.
Jennings claimed Patton misrepresented settlement discussions to the district attorney and the sheriff's investigator, prompting an investigation and arrest.
A 1997 settlement negotiation included Jennings releasing Patton and the district court reinstating a $35,000 judgment in exchange for Patton's $25,000 payment; Jennings and Shelton disputed the content of these negotiations.
An arrest warrant was issued and Jennings was arrested two days after the signed discussions were recorded; an Iles affidavit supported the charges.
Jennings and Shelton were indicted by a Mississippi grand jury in 1997 for bribery of a judge; the cases were ultimately remanded with prejudice in 2005 for lack of prosecutive merit.
Jennings filed a 42 U.S.C. § 1983 action alleging violations of Fourth and Fourteenth Amendments; Patton moved for dismissal/summary judgment based on immunity, which the district court denied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Patton is entitled to qualified immunity on the §1983 claim	Jennings claims misrepresentation violated constitutional rights and caused prosecution without probable cause.	Patton's actions were shielded by qualified immunity; causation is not shown due to independent intermediary.	Patton entitled to qualified immunity; district court's denial is reversed.
Whether the independent intermediary doctrine defeats causation for a Fourth Amendment claim here	Deliberations tainted by Patton's misrepresentation taint the magistrate/grand jury.	Independent intermediary broke the chain of causation; Patton did not prepare the warrant or testify before the grand jury.	Intermediary doctrine applied; no constitutional violation established.

Castellano v. Fragozo, 352 F.3d 939 (5th Cir.2003) (initiation of charges without probable cause may implicate constitutional rights when coupled with subsequent events)
Cuadra v. Houston Indep. Sch. Dist., 626 F.3d 808 (5th Cir.2010) (independent intermediary doctrine limits liability when a magistrate or grand jury decides based on information provided)
Michalik v. Hermann, 422 F.3d 252 (5th Cir.2005) (liability not extended to non-authoring individuals who did not prepare the warrant)
Hampton v. Oktibbeha Cnty. Sheriff Dept., 480 F.3d 358 (5th Cir.2007) (jurisdiction to review qualified-immunity denials is limited to legal questions)
Pearson v. Callahan, 555 U.S. 223 (2009) (two-step qualified-immunity analysis; constitutional right must be clearly established)