Lanning v. City of Glens Falls
908 F.3d 19
| 2d Cir. | 2018Background
- In 2012 David Lanning was arrested twice (May 24 and September 18) and later charged and indicted on contempt and harassment counts after allegations by his estranged wife and her partner, Glens Falls officer Ryan Ashe.
- Charges from both incidents were ultimately dismissed: one set after a jury trial (dismissal unspecified), and the Glens Falls charges dismissed “in the interest of justice” under N.Y. Crim. Proc. Law § 170.40. Several traffic tickets from a separate stop were also dismissed.
- Lanning sued under 42 U.S.C. § 1983 alleging malicious prosecution (Fourth Amendment) for the two arrests and a traffic stop, and an Equal Protection claim (Fourteenth Amendment) for selective enforcement; he also asserted Monell claims against municipal defendants.
- The district court granted judgment on the pleadings for defendants, dismissing the malicious prosecution and equal protection claims; Lanning appealed.
- On appeal the Second Circuit addressed whether federal § 1983 malicious-prosecution claims must follow New York’s more recent favorable-termination standard or the traditional common-law rule requiring an affirmative indication of innocence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standard for "favorable termination" in § 1983 malicious-prosecution claims | New York Court of Appeals permits any termination that is not inconsistent with innocence (i.e., Cantalino/Smith-Hunter standard) | Federal § 1983 claims require the traditional common-law standard: termination must indicate innocence | Held: Federal law controls; plaintiff must plead a termination that affirmatively indicates innocence |
| Application to Lanning’s dismissals | The dismissals (including §170.40 dismissal and unspecified jury-trial dismissal) satisfy favorable termination under NY rule | Dismissals here are at best procedural/neutral and do not indicate innocence | Held: Pleadings do not plausibly show terminations indicating innocence; malicious-prosecution claims fail |
| Equal Protection (selective enforcement / class-of-one) | Lanning contends he was singled out because of wife’s relationship with Ashe | Defendants argue no similarly situated comparators alleged | Held: Dismissed—complaint lacks plausible similarly situated comparators |
| Monell liability for municipal defendants | (derivative) Lanning argues municipal policies/practices enabled violations | Defendants: no underlying constitutional violation, so no Monell liability | Held: Monell claims dismissed because no plausible underlying constitutional violation |
Key Cases Cited
- Manuel v. City of Joliet, 137 S. Ct. 911 (2017) (federal courts should look to common-law tort principles to define §1983 elements but not be bound by state law; focus on constitutional values)
- Singleton v. City of New York, 632 F.2d 185 (2d Cir. 1980) (§1983 malicious-prosecution claim requires termination that indicates innocence)
- Jocks v. Tavernier, 316 F.3d 128 (2d Cir. 2003) (§1983 malicious-prosecution claims are substantially similar to state tort law but federal law defines elements)
- Swartz v. Insogna, 704 F.3d 105 (2d Cir. 2013) (elements of §1983 malicious-prosecution claim include favorable termination)
- Hygh v. Jacobs, 961 F.2d 359 (2d Cir. 1992) (dismissal in the interest of justice that leaves guilt unanswered does not satisfy favorable termination)