Raymond Nichols v. Daniel MacIas
695 F. App'x 291
| 9th Cir. | 2017Background
- On March 9, 2013, Raymond and Daniel Nichols were arrested by Riverside police for allegedly stealing an air mattress rented for their mother, Waly Nichols; they were released the next day and no charges were filed.
- The mattress had been at a rehabilitation center; the rental invoice listed the rehab center as the customer address and prohibited moving equipment without the rental company’s explicit approval.
- A rehab nurse told officers the brothers took the mattress before she confirmed rental-company permission and that a replacement mattress was to be delivered to Waly’s home that day.
- Daniel later returned to the rehab center with the mattress and the rental agreement, and the brothers said they had permission from the rental company to move the mattress to Waly’s home.
- The brothers sued under 42 U.S.C. § 1983 for unlawful arrest (Fourth Amendment); the district court granted summary judgment for the officers based on probable cause/qualified immunity.
- The Ninth Circuit vacated and remanded, finding disputed facts precluded a finding of probable cause as a matter of law and directing further qualified-immunity analysis.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether officers had probable cause to arrest for grand theft | Nichols: facts show ambiguity about permission; no probable cause for specific intent to permanently deprive | Officers: nurse’s account and rental terms supported a reasonable belief the brothers lacked permission and intended theft | Court: Probable cause not established as a matter of law given disputed facts; summary judgment vacated |
| Whether specific intent element of grand theft was satisfied for arrest | Nichols: no evidence officers had probable cause to infer specific intent to permanently deprive | Officers: brothers’ conduct and rental contract supported reasonable inference of intent | Court: Specific intent unresolved on the record; officer must have probable cause as to intent—disputed here |
| Whether qualified immunity shields officers | Nichols: officers violated Fourth Amendment and immunity not established because probable cause is contested | Officers: asserted qualified immunity because they reasonably believed probable cause existed | Court: District court only addressed probable cause; Ninth Circuit vacated summary judgment and remanded to analyze qualified immunity’s second prong under disputed facts |
| Proper standard on summary judgment for unlawful arrest | Nichols: factual disputes must be viewed in plaintiff’s favor; cannot grant summary judgment | Officers: argued evidence supported an objective reasonable officer finding | Court: Applied de novo review and held genuine disputes preclude resolving probable cause as a matter of law |
Key Cases Cited
- Torres v. City of Madera, 648 F.3d 1119 (9th Cir. 2011) (standard of review for § 1983 unlawful-arrest claims)
- Rosenbaum v. Washoe Cty., 663 F.3d 1071 (9th Cir. 2011) (probable cause when facts would lead a reasonably prudent person to believe a crime occurred)
- Rodis v. City & Cty. of San Francisco, 558 F.3d 964 (9th Cir. 2009) (officer must have probable cause as to specific-intent element when required)
- Castillo-Cruz v. Holder, 581 F.3d 1154 (9th Cir. 2009) (defining grand theft’s required intent in California)
- Reed v. Lieurance, 863 F.3d 1196 (9th Cir. 2017) (summary-judgment error where court failed to draw all reasonable inferences in plaintiff’s favor)