Mary Pritchard v. Hamilton Township Board of Trustees, 424 F. App'x 492

Pritchards own a home in Hamilton Township, Ohio; the party occurred August 10, 2007 to celebrate two birthdays.
Officers conducted a planned, nighttime operation monitoring potential underage drinking, including a plan to end at midnight with Liquor Control support.
Anonymous tips and prior observations prompted investigators to surveil the Pritchard property; no exigent circumstances justified entry at the outset.
Officer Gilbert allegedly entered the backyard curtilage without a warrant; Lt. Johnson allegedly joined a foot pursuit and entered the curtilage.
The pursuit led to the arrest of Zac Christman (underage) and Kevin Clark (recording), with charges later dismissed; plaintiffs allege unlawful search, false arrest, and related civil claims.
Plaintiffs asserted supervisory liability against Lt. Braley and Chief Richardson; Gail Gilbert was alleged to be a private actor joining a civil conspiracy; state-law immunity defenses were raised by Johnson and Gilbert.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the curtilage entry without a warrant violated the Fourth Amendment	Pritchards; Gilbert entered curtilage without justification	Gilbert relied on knock-and-talk and exigent circumstances	Qualified immunity denied; factual disputes remain for jury
Whether Clark and Christman were lawfully arrested with probable cause	Officers lacked probable cause for underage drinking or disorderly conduct	Arrests could be reasonable based on the information known	Qualified immunity denied for Clark; for Christman, lack of probable cause negates qualified immunity
Whether there was civil conspiracy among officers and Gail Gilbert	Evidence shows a plan to raid and concealment; actionable conspiracy	No showing of overt act or agreement; private actor immunity	Qualified immunity denied; conspiracy claim survives
Whether Ohio statutory immunity bars the state-law claims	Plaintiffs plead malice/wanton conduct exceptions to immunity	Exceptions do not apply; acts within scope	Statutory immunity denied; material facts dispute viability of malice/wanton standards

Payton v. New York, 445 U.S. 573 (U.S. 1980) (home-entry protections; warrantless searches presumptively unreasonable in curtilage)
United States v. Dunn, 480 F.3d 1219 (6th Cir. 2005) (courtilage factors for determining curtilage proximity and privacy)
Jacob v. Township of West Bloomfield, 531 F.3d 385 (6th Cir. 2008) (backyard is curtilage; Fourth Amendment protections apply)
Widgren v. Maple Grove Twp., 429 F.3d 575 (6th Cir. 2005) (curtilage includes cleared areas surrounding home)
Daughenbaugh v. City of Tiffin, 150 F.3d 596 (6th Cir. 1998) (curtilage considerations in Fourth Amendment context)
United States v. Jenkins, 124 F.3d 768 (6th Cir. 1997) (curtilage boundaries and surveillance)
Everson v. Leis, 556 F.3d 484 (6th Cir. 2009) (probable cause and qualified immunity; totality of information)
Pearson v. Callahan, 129 S. Ct. 808 (2009) (modifies Saucier sequencing; considerations on reasonableness and law)
Fridley v. Horrighs, 291 F.3d 867 (6th Cir. 2002) (affirmative defense/justification for arrest; statutory exemptions)
Painter v. Robertson, 185 F.3d 557 (6th Cir. 1999) (statutory affirmative defenses affecting probable cause)
Dietrich v. Burrows, 167 F.3d 1007 (6th Cir. 1999) (statutory defenses as part of probable cause analysis)
Kennedy v. City of Villa Hills, 635 F.3d 210 (6th Cir. 2011) (imputing knowledge of law to officers for Fourth Amendment analysis)
Holzemer v. City of Memphis, 621 F.3d 512 (6th Cir. 2010) (binding precedent on notice of law for officers)