Richard Wesley v. Alison Campbell
864 F.3d 433
| 6th Cir. | 2017Background
- Plaintiff Richard Wesley, a school counselor, was accused by a 7-year-old student (J.S.) of sexual abuse; allegations varied and included inconsistent details and a negative medical exam.
- Detective Joanne Rigney investigated, obtained an arrest-warrant affidavit based primarily on J.S.’s statements, and omitted several potentially exculpatory facts (e.g., office layout, door ajar, lack of corroboration, J.S.’s psychological history).
- A magistrate issued a warrant; Wesley was arrested 84 days after the first allegation; charges were dismissed months later. Wesley thereafter sued under 42 U.S.C. § 1983 for false arrest and sought damages, including punitive damages.
- At trial a jury found Rigney lacked probable cause, that she omitted material facts deliberately or with reckless disregard, and awarded $589,000 in compensatory and $500,000 in punitive damages.
- Rigney moved for directed verdict/new trial and for remittitur; the district court denied those motions. The Sixth Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Probable cause / False arrest | Wesley: affidavit omitted material, exculpatory evidence making J.S. unreliable, so no probable cause | Rigney: J.S.’s statements and prosecutor review provided probable cause | Held: Jury reasonably found no probable cause; verdict upheld |
| Qualified immunity | Wesley: deliberate/reckless omissions vitiate entitlement to immunity | Rigney: reasonable officer could have believed probable cause existed, and prosecutor reviewed affidavit | Held: Right was clearly established; jury reasonably found reckless/deliberate omissions; no immunity |
| Jury instructions (qualified immunity; J.S. psychological history) | Wesley: jury should consider J.S. reliability including psychological history | Rigney: instructions improperly allowed consideration of psychological history and omitted a reasonableness instruction for immunity | Held: District court did not abuse discretion; qualified immunity is a legal question for the judge and psychological-history factor was appropriate per prior guidance |
| Punitive & compensatory damages remittitur | Wesley: damages reflected humiliation, PTSD, lost employment opportunities | Rigney: awards excessive and not supported (lost wages assertedly unrelated) | Held: Punitive award constitutional (reprehensibility, ratio, comparable cases); compensatory and punitive awards not remitted |
Key Cases Cited
- Sykes v. Anderson, 625 F.3d 294 (6th Cir. 2010) (elements of false arrest claim)
- Pearson v. Callahan, 555 U.S. 223 (2009) (qualified immunity framework)
- Beck v. Ohio, 379 U.S. 89 (1964) (probable cause standard)
- Gardenhire v. Schubert, 205 F.3d 303 (6th Cir. 2000) (consider both inculpatory and exculpatory evidence for probable cause)
- Ahlers v. Schebil, 188 F.3d 365 (6th Cir. 1999) (duty to investigate/exculpatory evidence)
- Gregory v. City of Louisville, 444 F.3d 725 (6th Cir. 2006) (officer not protected when magistrate’s probable-cause finding rests on officer’s material misrepresentations)
- Vakilian v. Shaw, 335 F.3d 509 (6th Cir. 2003) (liability for knowingly or recklessly false statements to establish probable cause)
- Crawford-El v. Britton, 523 U.S. 574 (1998) (qualified immunity is objective; subjective intent irrelevant)
- Romanski v. Detroit Entm’t, L.L.C., 428 F.3d 629 (6th Cir. 2005) (analysis of reprehensibility and punitive-damages limits)
- BMW of N. Am., Inc. v. Gore, 517 U.S. 559 (1996) (guideposts for punitive-damages excessiveness)
- State Farm Mut. Auto. Ins. Co. v. Campbell, 538 U.S. 408 (2003) (single-digit ratio guidance for punitive damages)