Rashied Goodwin v. Edward Conway
2016 U.S. App. LEXIS 16656
3rd Cir.2016Background
- In Sept–Oct 2009 undercover Detective Lissner bought heroin twice from a seller called “Snipe”; other task-force detectives observed the buys and reports described Snipe as a Black male matching Goodwin’s description.
- Plainfield police identified “Snipe” as Rashied Goodwin; Lissner positively identified Goodwin from a jail photograph and initialed the photo.
- Detectives submitted an affidavit and supporting materials (investigative reports and the identified photograph) and obtained an arrest warrant; Goodwin was detained, later indicted, then charges were dropped when his counsel sought an exact date for the first buy.
- Goodwin asserted he was jailed on Sept. 26, 2009 and that a Plainfield booking sheet in the detectives’ file (listing nickname “Snipe” and showing detention beginning Sept. 26) would have provided a potential alibi for the first buy.
- Defendants conceded at oral argument they had the booking sheet when they applied for the warrant; the sole question became whether that sheet and reasonable inferences from it defeated probable cause.
- The Third Circuit held the booking sheet was not plainly exculpatory and did not obligate further investigation given the totality of inculpatory evidence (photo ID, corroborating reports), and therefore defendants had probable cause and qualified immunity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether detectives lacked probable cause because they omitted booking-sheet evidence indicating Goodwin was jailed during first buy | Goodwin: booking sheet showed he was incarcerated on relevant date, providing a potential alibi that would negate probable cause | Detectives: other corroborating evidence (two buys, independent ID, nickname match) supported probable cause despite the booking sheet | Held: No. The booking sheet was not plainly exculpatory and did not negate probable cause given the totality of evidence |
| Whether possessing the booking sheet imposed a duty to further investigate release date before seeking a warrant | Goodwin: detectives should have confirmed release date because the sheet raised obvious doubts | Detectives: sheet only showed detention starting Sept. 26 with no release date; other evidence made further inquiry unnecessary | Held: No duty to further investigate here; further inquiry not required absent obvious reason to doubt accuracy of ID/evidence |
| Whether omissions/reckless disregard occurred such that the warrant was procured by false statements/omissions | Goodwin: concealing the booking-sheet information was a reckless omission material to probable cause | Detectives: they did not deliberately or recklessly omit material facts; booking sheet was at worst ambiguous and partly inculpatory | Held: No reckless omission shown; submission did not create a falsehood that destroyed probable cause |
| Whether defendants are entitled to qualified immunity on false imprisonment and malicious prosecution claims | Goodwin: lack of probable cause defeats immunity | Detectives: they had probable cause; alternatively immunity applies if right was not clearly established | Held: Defendants entitled to qualified immunity because probable cause existed; indictment also supports probable cause for prosecution claim |
Key Cases Cited
- Mitchell v. Forsyth, 472 U.S. 511 (recognizing appealability of qualified immunity questions)
- Pearson v. Callahan, 555 U.S. 223 (qualified immunity two-step inquiry)
- Ashcroft v. al-Kidd, 563 U.S. 731 (clearly established law prong of qualified immunity)
- Wilson v. Russo, 212 F.3d 781 (3d Cir.) (standards for false arrest claims based on warrants; material omissions)
- Reedy v. Evanson, 615 F.3d 197 (3d Cir.) (example of disregarding plainly exculpatory evidence)
- United States v. Yusuf, 461 F.3d 374 (3d Cir.) (when information should trigger further investigation)
- Rose v. Bartle, 871 F.2d 331 (3d Cir.) (grand-jury indictment as prima facie evidence of probable cause)