Ryan Crostley v. Lamar County Texas
2013 U.S. App. LEXIS 10850
| 5th Cir. | 2013Background
- Appellants Crostley and Finley were arrested for murder following a Lamar County–led investigation; charges were later dropped.
- District court dismissed all claims against Lamar County with prejudice; Appellants sought leave to amend to add Lamar County again and Keele after the deadline.
- Keele, Kain, Tuttle, and Barr conducted the initial investigation; affidavits for arrest warrants relied on a mix of statements and circumstantial evidence.
- New information surfaced post-arrest, including recantations and additional statements; by June 2009 all charges against Crostley and Finley were dropped.
- Appellants filed § 1983 claims for false arrest, false imprisonment, malicious prosecution, and defamation; district court granted summary judgment on qualified immunity for Brooks and McNeal.
- Appellants appeal district court’s denial of leave to amend as to Lamar County and Keele, and the summary judgments for Brooks and McNeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court abused its discretion by denying leave to amend to add Lamar County. | Crostley and Finley contends remaining party status supports amendment. | District court found amendments futile due to statute of limitations and finality rules. | Abuse of discretion; remand for amendment as to Lamar County. |
| Whether the district court abused its discretion by denying leave to amend to add Keele. | Keele’s late involvement and investigation facts justify amendment. | Statute of limitations barred claims; no relation back or tolling applicable. | Affirmed denial as to Keele. |
| Whether summary judgment on false arrest claims against Brooks and McNeal was proper. | Probable cause lacked; witnesses’ statements and inconsistent evidence show failure. | Totality of circumstances supported probable cause; objectively reasonable belief in arrest. | Granted in favor of Brooks and McNeal; qualified immunity. |
| Whether summary judgment on the malicious prosecution claim against Brooks was proper, and whether official immunity applies to state-law claims. | Malicious prosecution triggered by improper investigation and arrest. | Official immunity bars state-law claim when actions were discretionary and taken in good faith. | Affirmed official-immunity defense; malicious-prosecution claim barred. |
Key Cases Cited
- Beck v. Ohio, 379 U.S. 89 (U.S. Supreme Court 1964) (probable cause and totality-of-circumstances review for arrests)
- Illinois v. Gates, 462 U.S. 213 (U.S. Supreme Court 1983) (probable cause standard based on totality of circumstances; hearsay admissibility)
- Pearson v. Callahan, 555 U.S. 223 (U.S. Supreme Court 2009) (two-prong qualified immunity analysis; order of inquiries flexible)
- Harris v. Boyd Tunica, Inc., 628 F.3d 237 (5th Cir. 2010) (equitable tolling limitations for amendments; rare circumstances)
- Briargrove Shopping Ctr. v. Pilgrim Enters., 170 F.3d 536 (5th Cir. 1999) (Rule 54(b) final judgments and appellate jurisdiction standards)