Robinson v. Cook
2013 U.S. App. LEXIS 1532
1st Cir.2013Background
- Two 13-year-old boys described a silver/tan two-door Honda with a rubber strip as the hit-and-run vehicle near Attleboro.
- The car was found in the Robinsons’ driveway within a mile of the scene and matched the description with a warm engine.
- Police seized Robert’s Honda from the driveway and arrested Mario and Robert after interviews and identifications by the boys.
- The boys identified the Honda and Mario as the passenger; Robert was identified as the driver by the boys over the course of the investigation.
- All charges were ultimately dismissed; the Robinsons sued for constitutional and state-law claims, and the district court granted summary judgment to most defendants.
- The First Circuit affirmed, ruling the seizure and arrests were supported by probable cause and that Monell and IIED claims failed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the car seizure constitutional | Robinsons argue lack of probable cause and no exigency on private driveway | Car matched description, close proximity to scene, and warmth supported probable cause and exigency | Seizure constitutional; probable cause and exigency supported |
| Were Mario and Robert's arrests constitutional | Insufficient probable cause for arrest for any crime | Probable cause based on identifications and car location; immediate aftermath supports arrest | Arrests supported by probable cause |
| Can the claims support Monell liability | Municipality liable for officer conduct | No underlying constitutional harm proven; no Monell liability | Monell liability rejected |
| Does the record support a claim of intentional infliction of emotional distress | Possible extreme conduct by officers during processing | No extreme or outrageous behavior shown | IIED claim rejected |
Key Cases Cited
- Maryland v. Dyson, 527 U.S. 465 (U.S. 1999) (automobile exception does not require a separate exigency)
- Massachusetts v. Labron, 518 U.S. 938 (U.S. 1996) (exigent circumstances not required by automobile exception)
- Chambers v. Maroney, 399 U.S. 42 (U.S. 1970) (probable cause supports vehicle seizure near crime scene)
- Jones v. United States, 432 F.3d 34 (1st Cir. 2005) (probable cause for arrest evaluated on totality of circumstances)
- Santaliz v. City of Providence, 596 N.E.2d 337 (Mass. 1992) (Mass. probable-cause standard mirrors Fourth Amendment)
- Roche v. John Hancock Mut. Life Ins. Co., 81 F.3d 249 (1st Cir. 1996) (probable-cause analysis uses trustworthy information, not perfect accuracy)
- Stovall v. Denno, 388 U.S. 293 (U.S. 1967) (show-up identifications considered in reliability analysis)
- Brathwaite, 432 U.S. 98 (U.S. 1977) (reliability factors for eyewitness identifications in totality-of-circumstances)
- Perry v. New Hampshire, 132 S. Ct. 716 (S. Ct. 2012) (limits on the admissibility of eyewitness identifications in trials, not civil §1983 issues)