Michael Kinlin v. Shawn Kline
749 F.3d 573
6th Cir.2014Background
- On March 11, 2011 Trooper Kline observed Michael Kinlin make a sudden lane change into a narrow gap, then stopped him for an alleged unsafe lane change and crossing center line.
- On contact Kline asked about alcohol; Kinlin admitted drinking two beers and appeared disheveled; Kline smelled alcohol and noted glassy eyes.
- Kinlin initially refused field sobriety testing (refused three times) but later agreed while being patted down; a subsequent breath test showed BAC .012%.
- Kinlin sued under 42 U.S.C. § 1983 alleging Fourth Amendment violations for an unlawful stop and an unlawful arrest.
- The district court granted summary judgment for Trooper Kline, holding video evidence established probable cause for the stop and that the totality of circumstances (unsafe lane change, odor of alcohol, admission of drinking, refusal to test) established probable cause for arrest; Kline invoked qualified immunity.
- The Sixth Circuit affirmed, concluding the stop and arrest were supported by probable cause and qualified immunity applied.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Probable cause for traffic stop | Kinlin: video does not show crossing center line and signaling made the lane change lawful | Kline: video shows an unsafe lane change into a tight gap that caused another car to brake, giving probable cause under Ohio law | Stop upheld: video objectively shows an unsafe lane change; Kline had probable cause to stop |
| Probable cause for arrest (DUI) | Kinlin: officer ignored exculpatory facts (steady on feet, not slurring) and improperly focused on incriminating facts | Kline: lane change + odor of alcohol + admission of drinking + repeated refusal to take FSTs provided probable cause to arrest | Arrest upheld: totality of circumstances gave probable cause; qualified immunity protects Kline |
Key Cases Cited
- Scott v. Harris, 550 U.S. 372 (video evidence may preclude contrary factual claims at summary judgment)
- Whren v. United States, 517 U.S. 806 (traffic stop reasonable when officer has probable cause of traffic violation)
- Burgess v. Fischer, 735 F.3d 462 (qualified immunity summary-judgment standard)
- United States v. Akram, 165 F.3d 452 (Ohio law: signaling and unsafe lane change are distinct violations)
- Green v. Throckmorton, 681 F.3d 853 (field sobriety failures alone may be insufficient, but context matters)
- Wilder v. Turner, 490 F.3d 810 (refusal to perform FSTs plus alcohol indicators can support probable cause)
- Miller v. Harget, 458 F.3d 1251 (refusal combined with smell of alcohol can support probable cause)
- Criss v. City of Kent, 867 F.2d 259 (a valid arrest based on probable cause is not negated by later proof of innocence)