Loftin v. City of Prentiss, MS, 33 F.4th 774

Background

On April 17, 2017, Joshua Loftin shot Dontarious Walker after confronting Walker about loud music; Loftin told police he shot in self‑defense because Walker brandished a handgun.
Bystanders at the scene identified Loftin as the shooter; an unrelated man (McInnis) fled and discarded a Glock‑style pistol, but officers familiar with McInnis believed he was not involved.
Officers Jones and Chief Bullock arrested Loftin for aggravated assault without a warrant; Bullock later obtained search warrants and an arrest warrant supported by an affidavit that did not mention Loftin’s self‑defense claim or the discarded gun.
Loftin was indicted, convicted by a jury, then granted a new trial; charges were later nolle prossed and dismissed.
Loftin sued under 42 U.S.C. § 1983 (false arrest, Franks challenge to affidavit, Monell failure‑to‑train/policy), plus state malicious prosecution; the district court granted summary judgment for defendants and awarded attorneys’ fees.
The Fifth Circuit affirmed summary judgment and the fee award.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Warrantless arrest / probable cause & qualified immunity	Loftin argued officers lacked probable cause because he immediately told them he shot in self‑defense and there was no evidence to contradict that claim	Officers relied on bystanders identifying Loftin as shooter, Loftin’s admissions to police, and other facts establishing probable cause; even if not, qualified immunity applies	Arrest was supported by probable cause; alternatively officers entitled to qualified immunity
Franks / omitted facts from arrest‑warrant affidavit	Chief Bullock omitted material exculpatory facts (self‑defense claim; McInnis’s discarded gun) that would vitiate probable cause	Even with omitted facts added, the affidavit still supplied probable cause; omitted facts not material	No Franks violation; omissions were not material
Monell municipal liability	City had policies/customs and training failures that caused false arrest	No underlying constitutional violation, so no Monell liability	Monell claim fails for lack of predicate constitutional violation
State malicious prosecution	Loftin argued want of probable cause and malice supported malicious prosecution claim	Defendants argued probable cause existed for initiation/continuation of proceedings	Malicious prosecution fails because no lack of probable cause shown
Attorneys’ fees under § 1988	Loftin argued fee award was improper	Defendants argued plaintiff’s claims were frivolous/unreasonable given undisputed facts	District court did not abuse discretion in awarding fees; claim lacked factual basis

Key Cases Cited

District of Columbia v. Wesby, 138 S. Ct. 577 (Sup. Ct. 2018) (probable cause standard and treatment of innocent explanations)
Devenpeck v. Alford, 543 U.S. 146 (Sup. Ct. 2004) (probable cause for warrantless arrest)
Maryland v. Pringle, 540 U.S. 366 (Sup. Ct. 2003) (examination of facts known to officer for probable cause)
Illinois v. Gates, 462 U.S. 213 (Sup. Ct. 1983) (probable cause requires a probability, not certainty)
Kaley v. United States, 571 U.S. 320 (Sup. Ct. 2014) (grand jury/probable cause and reliability without adversarial hearing)
Franks v. Delaware, 438 U.S. 154 (Sup. Ct. 1978) (challenge to warrants based on false statements or intentional/reckless omissions)
Terwilliger v. Reyna, 4 F.4th 270 (5th Cir. 2021) (independent‑intermediary doctrine and exceptions for false or omitted material information)
Kohler v. Englade, 470 F.3d 1104 (5th Cir. 2006) (test for materiality of omitted facts in affidavit reconstruction)
Merced v. Kasson, 577 F.3d 578 (5th Cir. 2009) (standards for awarding attorneys’ fees to prevailing § 1983 defendants)