44 F.4th 1111
8th Cir.2022Background
- On June 19–20, 2017, Des Moines officers responding to a trespass/key-fob complaint entered Michael Klein’s apartment, asked for IDs, and inspected personal items.
- Officer Steinkamp opened a Crown Royal bag (finding empty baggies) and used a key from collected key chains to open a lock box that contained Klein’s ID, a digital scale, and a white crystalline substance later confirmed by lab testing as >9 grams of methamphetamine.
- Klein was arrested and charged with possession with intent to deliver (>5 g) and failure to possess a tax stamp (7 g threshold); he was detained, moved to suppress, and the county attorney dismissed the prosecution on November 7, 2017.
- Klein sued Steinkamp (removed to federal court) on November 6, 2019 asserting unlawful seizure, false arrest, and malicious prosecution under federal and Iowa law.
- The district court granted Steinkamp summary judgment; the Eighth Circuit affirmed, holding the seizure and false-arrest claims untimely and the malicious-prosecution claim lacking on the merits because probable cause existed.
- The court also held that evidence known to the arresting officer may be considered in evaluating probable cause even if that evidence would be inadmissible at trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Timeliness of false arrest/unlawful seizure under Iowa law | Accrual extends through confinement/release (relying on Children) | Injury/claim accrued at arrest (June 19/20/2017); two-year statute expired before Nov 2019 filing | Accrual at arrest; Iowa claims untimely |
| Timeliness of § 1983 claims | Same accrual argument; claim timely | Federal accrual rules: seizure accrues on date of seizure (June 19); false arrest accrues when bound over (June 20); two-year limitations expired | Federal claims untimely |
| Malicious prosecution (probable cause and effect of potentially unlawful search) | No probable cause; search/entry violated Fourth Amendment; officer’s estimate showed only ~5–6 g | Officer observed scale, ID, and quantity visually consistent with a drug-trafficking offense; lab confirmed >9 g; probable cause is objective and may consider all information known to officer | Probable cause existed for both charged offenses; malicious prosecution fails |
Key Cases Cited
- Venckus v. City of Iowa City, 930 N.W.2d 792 (Iowa 2019) (Iowa municipal-employee claims must be brought within two years)
- Doe v. New London Cmty. Sch. Dist., 848 N.W.2d 347 (Iowa 2014) (accrual occurs at time of the wrongful act)
- Children v. Burton, 331 N.W.2d 673 (Iowa 1983) (probable-cause analysis considers facts known during confinement; evidence inadmissibility does not control civil probable-cause inquiry)
- Wallace v. Kato, 549 U.S. 384 (2007) (false-arrest § 1983 claim accrues when the arrestee is bound over for trial)
- Thompson v. Clark, 142 S. Ct. 1332 (2022) (malicious prosecution is actionable under the Fourth Amendment)
- Devenpeck v. Alford, 543 U.S. 146 (2004) (probable cause is an objective inquiry; officer’s subjective reasons are not dispositive)
- Veatch v. Bartels Lutheran Home, 627 F.3d 1254 (8th Cir. 2010) (definition of probable cause for Fourth Amendment claims)
- Sisler v. City of Centerville, 372 N.W.2d 248 (Iowa 1985) (Iowa standard for probable cause in malicious-prosecution context)