Ronald Fidge v. Lake County Sheriff's Dept., 683 F. App'x 605

Ronald Fidge sued under 42 U.S.C. § 1983 after being arrested for trespassing; he proceeded pro se and appealed the district court’s grant of summary judgment against him.
Primary defendants included Deputy Wright (arresting officer) and private individuals Gaskell, Hardester, and Harper; Lake County was also a defendant on state-law false imprisonment theory.
Fidge alleged unlawful arrest (lack of probable cause), excessive force (use of less-lethal force), Monell municipal liability, and false imprisonment; he also raised procedural complaints about hearsay and judicial bias.
District court granted summary judgment for Deputy Wright on unlawful arrest, excessive force, and false imprisonment claims; granted summary judgment for the private individuals on § 1983 claims for lack of action under color of state law; denied Fidge’s other motions.
On appeal the Ninth Circuit reviewed de novo and affirmed: no genuine disputes of material fact as to probable cause, excessive force, or Monell liability; private parties did not act under color of law; Lake County’s claim failed because no underlying officer liability.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Wright arrested Fidge without probable cause	Fidge contends arrest lacked probable cause	Wright contends facts known to him established fair probability of a crime	Arrest was supported by probable cause; summary judgment affirmed
Whether Wright used excessive force in arrest	Fidge contends less-lethal force was unreasonable	Wright contends force was reasonable under Graham factors	No genuine dispute that force was reasonable; summary judgment affirmed
Whether private individuals acted under color of state law (§ 1983)	Fidge contends Gaskell/Hardester/Harper willfully joined state action	Defendants contend they were private actors not engaged in joint action with state officials	No evidence of willful joint action; summary judgment for private defendants affirmed
Whether Lake County is liable (Monell / state false imprisonment)	Fidge alleges municipal/custom liability and county vicarious liability	County argues no underlying constitutional violation and no policy/custom caused harm	Monell claim failed (no officer-level violation and no policy/custom); false imprisonment claim fails because no underlying liability; affirmed

Guatay Christian Fellowship v. County of San Diego, 670 F.3d 957 (9th Cir. 2011) (standard for de novo review of summary judgment issues in § 1983 appeals)
United States v. Gonzales, 749 F.2d 1329 (9th Cir. 1984) (probable cause exists when facts give a prudent person a fair probability a crime occurred)
United Steelworkers of Am. v. Phelps Dodge Corp., 865 F.2d 1539 (9th Cir. 1989) (private parties act under color of state law only when willfully participating in joint action with state officials)
Graham v. Connor, 490 U.S. 386 (1989) (Fourth Amendment excessive-force reasonableness requires case-specific Graham factors)
Monell v. Department of Social Services, 436 U.S. 658 (1978) (municipal liability under § 1983 requires an underlying constitutional violation and action pursuant to an official policy or custom)
City of Los Angeles v. Heller, 475 U.S. 796 (1986) (Monell liability unavailable when no constitutional injury by the individual officer)
Cameron v. Craig, 713 F.3d 1012 (9th Cir. 2013) (county vicarious liability for state-law claims if plaintiff prevails against county employee)