Jimenez v. Bogle, 24-323

Juan Jimenez was arrested in 2019 after B.M., a 12-year-old, accused him of sexual abuse, including inappropriate touching and attempted sexual acts.
He was charged under New York law with various offenses but was not indicted by a grand jury.
Jimenez sued under 42 U.S.C. § 1983, asserting claims of false arrest, malicious prosecution, and First Amendment retaliation against the City of New York and several officers.
The district court granted summary judgment to defendants, finding they had at least arguable probable cause and thus qualified immunity.
On appeal, Jimenez challenged only the summary judgment on his false arrest and malicious prosecution claims against three officers.

Issue	Plaintiff's Argument	Defendant's Argument	Held
False arrest	Officers lacked probable cause based on uncorroborated, inconsistent statements	Victim's consistent statements established arguable probable cause	Officers had arguable probable cause; summary judgment upheld
Malicious prosecution	No probable cause to initiate prosecution, especially after key inconsistencies	Probable cause is a complete defense; no exculpatory facts emerged later	Arguable probable cause existed; summary judgment affirmed
Credibility of victim	Victim admitted to sometimes lying; more investigation was required	Officers may rely on victim's account absent clear doubts about veracity	Minor inconsistencies did not negate probable cause
Qualified immunity	No reasonable officer could find probable cause under these facts	At least arguable probable cause existed, warranting qualified immunity	Qualified immunity applied to defendants

Fabrikant v. French, 691 F.3d 193 (2d Cir. 2012) (probable cause is a complete defense to false arrest and malicious prosecution claims)
Panetta v. Crowley, 460 F.3d 388 (2d Cir. 2006) (probable cause based on reasonably trustworthy information)
Figueroa v. Mazza, 825 F.3d 89 (2d Cir. 2016) (qualified immunity when any reasonable officer could deem the action lawful)
Curley v. Village of Suffern, 268 F.3d 65 (2d Cir. 2001) (officer with probable cause need not eliminate all claims of innocence before arrest)