R. Hall v. Det. B. Peters
248 C.D. 2017
| Pa. Commw. Ct. | Nov 30, 2017Background
- In March 2011 Robert Hall was arrested for the fatal shooting of Raheem Bennett after Detective Brian Peters prepared an affidavit of probable cause based largely on an identification by a close friend of the decedent (Primary Witness) and corroboration by Primary Witness’ brother (Witness M.T.).
- The affidavit did not mention a 911 call in which Primary Witness told the dispatcher he did not see the shooter; Hall was arrested the day after the affidavit was signed.
- Hall was tried twice for first-degree murder: the first trial ended in a mistrial; the second trial (after the defense was provided the 911 tape) resulted in acquittal; Hall spent ~30 months jailed.
- Hall sued Detective Peters for malicious prosecution, alleging intentional suppression/omission of exculpatory evidence (the 911 tape), inadequate investigation that vitiated probable cause, and willful misconduct; Peters moved for summary judgment.
- The trial court found Peters had probable cause based on eyewitness ID(s), held that alleged investigative imperfections and omission of the 911 tape (no proof Peters intentionally withheld it) went to weight not existence of probable cause, and that Hall failed to show malice or willful misconduct; the Commonwealth Court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Detective’s omission/suppression of the 911 tape vitiated probable cause | Omission of a highly relevant exculpatory 911 statement (Primary Witness said he didn’t see shooter) rendered the affidavit false and would have prevented a neutral magistrate from finding probable cause | The affidavit relied on a later, positive eyewitness ID and corroboration; the 911 statement went to credibility/weight, not to probable cause; no evidence Peters intentionally withheld the tape | Court: Omission did not vitiate probable cause; omission affected weight, not existence, of probable cause; no proof of intentional suppression |
| Whether Detective’s allegedly inadequate investigation negates probable cause | Failure to investigate leads, cell records, conflicting eyewitnesses, and departmental directive violations created a factual dispute whether probable cause existed | An imperfect or incomplete investigation does not negate probable cause; probable cause may rest on a single credible eyewitness and corroboration | Court: Investigation imperfections do not defeat probable cause; eyewitness ID plus corroboration sufficient |
| Whether malice or willful misconduct existed to support malicious prosecution / overcome immunity | Peters’ alleged intentional omission of exculpatory evidence, directive violations, and post-arrest conduct support inference of malice/willful misconduct | Probable cause existed (absolute defense); no evidence Peters intentionally withheld the 911 tape; isolated procedural lapses and unsupported allegations are insufficient to show willful misconduct | Court: Hall failed to present prima facie evidence of malice or willful misconduct; claim barred by existence of probable cause |
| Whether factual disputes required jury resolution of probable cause/malice on summary judgment | Hall: material facts are disputed and should preclude summary judgment | Peters: record shows no genuine dispute that probable cause existed; where facts aren't in controversy court decides probable cause as a matter of law | Court: De novo review — no genuine dispute that would defeat Peters’ showing; summary judgment affirmed |
Key Cases Cited
- Turano v. Hunt, 631 A.2d 822 (Pa. Cmwlth. 1993) (probable cause may be determined as a matter of law; single eyewitness may supply probable cause)
- Commonwealth v. Weidenmoyer, 539 A.2d 1291 (Pa. 1988) (probable cause deals with probabilities and presumes voluntary statements are trustworthy)
- Franks v. Delaware, 438 U.S. 154 (1978) (challenge to warrant based on false statements or material omissions in affidavit)
- Renk v. City of Pittsburgh, 641 A.2d 289 (Pa. 1994) (willful misconduct requires proof officer knew actions were wrongful and chose to act anyway)
- Manley v. Fitzgerald, 997 A.2d 1235 (Pa. Cmwlth. 2010) (elements of malicious prosecution and courts’ reluctance to permit such claims absent lack of probable cause)