Sargeant v. Bell, 9:15-cv-00116

Plaintiffs Mike Sargeant and Ryan Funke were accused in a revived investigation into an alleged poaching ring (the "Coyote Club"). A 2010 FWP investigation produced no charges; the investigation was reopened after new county officials took office in 2015.
Lake County Attorney Eschenbacher tasked Detective Lenz to re-investigate. Lenz's search-warrant application relied on over twenty witness statements, taxidermy records, payments by Sargeant, and a 2005 FWP report alleging unlawful taking of animals.
A Lake County District Court judge (Manley) reviewed the application and issued a warrant authorizing searches for unlawfully possessed mounts and hunting photographs at Sargeant’s, Funke’s, and a third residence.
Executing the warrant, officers seized seven whitetail mounts and a black bear rug from Sargeant’s home; photographs were taken at Funke’s after he voluntarily allowed the sheriff inside, but nothing was seized from Funke.
Sargeant and Funke sued in state court (removed to federal court), asserting Montana constitutional violations, 42 U.S.C. § 1983 Fourth/Fourteenth Amendment claims, negligent and intentional infliction of emotional distress, and seeking punitive damages and fees. Defendants moved for summary judgment; Magistrate Judge Anderson recommended granting it, and the district court adopted his findings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of search warrant / probable cause	Sargeant/Funke: affidavits lacked facts to show probable cause in 2015; evidence was speculative and no stronger than 2010 FWP file	LSCO: application contained numerous independent informant statements, taxidermy records, payments, and a 2005 report—totality supports probable cause; issuing judge entitled to deference	Court: probable cause existed under totality of circumstances; warrant valid; magistrate judge not in error
Particularity of warrant	Plaintiffs: challenged sufficiency of facts and particularity (argued warrant was overbroad/insufficient)	LSCO: application and warrant sufficiently identified places and items to be seized	Court: warrant satisfied particularity requirements; no constitutional violation
State-law tort claims (negligent/intentional infliction of emotional distress)	Plaintiffs: emotional/mental damages from searches and investigation	LSCO: actions were lawful under warrant; no negligent or intentional actionable conduct	Court: tort claims fail because underlying searches were lawful; summary judgment for defendants

McDonnell Douglas Corp. v. Commodore Bus. Mach., Inc., 656 F.2d 1309 (9th Cir. 1981) (standard for district court review of magistrate findings)
Thomas v. Arn, 474 U.S. 140 (1985) (standard for review of magistrate judge recommendations)
United States v. Syrax, 235 F.3d 422 (9th Cir. 2000) (defining "clear error" standard)
Montana v. Rinehart, 864 P.2d 1219 (Mont. 1993) (issuing judge entitled to deference on probable cause; review limited to four corners)
Illinois v. Gates, 462 U.S. 213 (1983) (totality-of-the-circumstances test for probable cause)
Montana v. Barnaby, 142 P.3d 809 (Mont. 2006) (practical, common-sense probable cause determination under totality test)