Renardo Hudson v. Kevin Knapp
685 F. App'x 740
| 11th Cir. | 2017Background
- On Feb. 20, 2013, Officer Kevin Knapp stopped and arrested Renardo Hudson while Hudson sat lawfully in his parked car in Atlanta, claiming Hudson matched an outstanding warrant for a Charles Gray.
- Knapp asserted Hudson’s identifying details and photo matched the warrant and that Hudson was listed as an alias for Gray; Hudson disputed all these points and produced his driver’s license, vehicle registration, and the Gray warrant to show mismatches and that Gray’s warrant had been administratively closed.
- Hudson told Knapp Gray was incarcerated; Knapp reportedly said, “I don’t care whether you are or not, I’m locking you up,” handcuffed Hudson tightly, and detained him in the patrol car and then at Fulton County Jail for about two days before release when deputies confirmed he was not Gray.
- Hudson sued under 42 U.S.C. § 1983 for false arrest (Fourth Amendment) and excessive force, and brought Georgia state claims for false imprisonment/excessive detention and intentional infliction of emotional distress.
- Knapp moved for summary judgment asserting federal qualified immunity and Georgia official immunity; the district court denied the motion and the Eleventh Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Knapp violated the Fourth Amendment by fabricating probable cause for arrest | Hudson: Knapp intentionally lied and fabricated matches to an arrest warrant, so arrest lacked probable cause | Knapp: He reasonably (though mistakenly) believed Hudson was Gray based on warrant information and thus had arguable probable cause | Held: Accepting Hudson’s version, Knapp fabricated probable cause; constitutional violation established |
| Whether Knapp is entitled to qualified immunity for the federal claims | Hudson: Right against fabrication of probable cause was clearly established; Knapp’s conduct falls outside immunity | Knapp: Reasonable mistake; district court ignored his evidence and credibility | Held: Fabricating facts to create probable cause was clearly established law; qualified immunity denied |
| Whether excessive-force claim stands separate from false arrest | Hudson: Excessive force resulted from the illegal arrest | Knapp: (Implicit) force justified by lawful arrest | Held: Excessive force claim is subsumed by illegal arrest claim (not treated as discrete) |
| Whether Knapp is protected by Georgia official immunity on state claims | Hudson: Knapp acted with actual malice by intentionally fabricating probable cause, defeating official immunity | Knapp: Actions discretionary and done to protect rights; no malice; immunity applies | Held: Evidence supports actual malice/deliberate intent to do wrong; official immunity denied |
Key Cases Cited
- Lee v. Ferraro, 284 F.3d 1188 (11th Cir. 2002) (standard for de novo review of qualified immunity summary-judgment rulings)
- Kingsland v. City of Miami, 382 F.3d 1220 (11th Cir. 2004) (fabricating evidence to establish probable cause is unconstitutional)
- Brown v. City of Huntsville, 608 F.3d 724 (11th Cir. 2010) (aroguable probable cause assessed by elements and operative facts)
- Wilkerson v. Seymour, 736 F.3d 974 (11th Cir. 2013) (focus on information known to officers at time of conduct)
- Rodriguez v. Farrell, 280 F.3d 1341 (11th Cir. 2002) (reasonable mistake of identity can negate constitutional violation if truly reasonable)
- Jackson v. Sauls, 206 F.3d 1156 (11th Cir. 2000) (excessive-force claim may be subsumed by illegal arrest claim)
- Harlow v. Fitzgerald, 457 U.S. 800 (U.S. 1982) (qualified immunity depends on clearly established law at time of conduct)
- Jenkins by Hall v. Talladega City Bd. of Educ., 115 F.3d 821 (11th Cir. 1997) (sources that can clearly establish law for qualified immunity)
- Cameron v. Lang, 549 S.E.2d 341 (Ga. 2001) (Georgia official immunity framework for discretionary acts)