Julius Goldring v. Vladimir Henry, 19-13820

Background

On Oct. 10, 2015, Atlanta officers Henry and Restrepo stopped Julius Goldring, alleged jaywalking, searched her purse (she consented), and found a stress ball containing a white powdery substance.
Officer Henry performed a NARK II field test at the station; Henry reported a "faint positive," but Goldring and another officer witnessed no meaningful color change; the powder was later found by the GBI not to be cocaine.
A magistrate issued an arrest warrant that day charging Goldring with jaywalking and trafficking in cocaine; she spent about five months in custody before the state dismissed charges.
Goldring sued under 42 U.S.C. § 1983 (malicious prosecution) and Georgia law, alleging the officers lacked (arguable) probable cause and knowingly or recklessly falsified the warrant affidavit.
The district court denied the officers’ summary-judgment motion for qualified and official immunity; the Eleventh Circuit affirmed, finding genuine disputes of material fact precluding immunity at summary judgment.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Qualified immunity for jaywalking-based malicious prosecution	Goldring: officers falsely alleged she was in the roadway; affidavit misstatement was intentional/reckless and was necessary to probable cause	Officers: they had (arguable) probable cause because they observed jaywalking	Denied — factual dispute whether officers lied about being in the street; if removed, affidavit lacks probable cause, so qualified immunity not appropriate at summary judgment
Qualified immunity for trafficking-in-cocaine charge (Officer Henry)	Goldring: Henry intentionally misreported a positive field test though the pouch never changed color; misstatement was necessary to probable cause	Henry: any error performing/interpreting NARK II was reasonable; he relied on his perception of test result	Denied — jury could infer Henry lied about a "faint positive"; without the test result there was no probable cause
Liability of Officer Restrepo for warrant/application	Goldring: Restrepo helped draft the narrative and spoke to the magistrate; thus he can be liable for misstatements	Restrepo: he merely arrested Goldring and relied on Henry’s account; prosecution began with the DA’s indictment	Denied (as to summary judgment) — obtaining the arrest warrant instituted prosecution; record supports jury inference Restrepo assisted and may have known result was negative
Official immunity under Georgia law (actual malice)	Goldring: evidence supports that officers knowingly lacked probable cause and thus acted with actual malice	Officers: arrest/investigation were discretionary and lacking evidence of deliberate intent to do wrong	Denied — factual disputes over officers’ state of mind preclude summary judgment on actual malice

Key Cases Cited

Ashcroft v. al-Kidd, 563 U.S. 731 (2011) (qualified immunity protects reasonable but mistaken judgments)
District of Columbia v. Wesby, 138 S. Ct. 577 (2018) (two-part qualified-immunity framework)
Manuel v. City of Joliet, 137 S. Ct. 911 (2017) (malicious prosecution can be a Fourth Amendment seizure when legal process is defective)
Williams v. Aguirre, 965 F.3d 1147 (11th Cir. 2020) (officers may lose qualified immunity when they knowingly include false statements necessary to probable cause)
Paez v. Mulvey, 915 F.3d 1276 (11th Cir. 2019) (delete intentional misstatements and evaluate remaining probable cause)
Luke v. Gulley, 975 F.3d 1140 (11th Cir. 2020) (overlap of Fourth Amendment seizure and malicious-prosecution elements)
Kingsland v. City of Miami, 382 F.3d 1220 (11th Cir. 2004) (distinguishing warrant-based prosecution from warrantless-arrest claims)
United States v. Kirk, 781 F.2d 1498 (11th Cir. 1986) (reliance on fellow officers’ observations can be a reliable basis for a warrant)
County of Riverside v. McLaughlin, 500 U.S. 44 (1991) (limits on post-arrest detention without judicial process)