Sidney Arnold v. Steven Williams
979 F.3d 262
5th Cir.2020Background
- Around 2:00 a.m., Deputy Steven Williams was observed under the carport of a house where Sidney Arnold lived in a garage apartment; Williams pointed to an open laundry-room door and asked Arnold for identification.
- The homeowner confirmed Arnold lived there; Williams nevertheless "reached to grab" Arnold after Arnold declined to go to the police car and said he would wake the homeowner.
- Arnold ran, fell over a backyard fence, dislocated his shoulder, was apprehended, jailed for 20 days, and later had all charges dropped for lack of probable cause.
- Arnold sued under 42 U.S.C. § 1983 (unreasonable search and seizure, false arrest/false imprisonment, malicious prosecution, Due Process) and under Louisiana tort law (negligence, intentional infliction of emotional distress).
- The district court dismissed most § 1983 and IIED claims under Rule 12(b)(6) and granted summary judgment for the deputy on negligence; the Fifth Circuit reversed the dismissal of the unreasonable-search claim and remanded for qualified-immunity analysis, and affirmed the district court in all other respects.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Unreasonable search (Fourth Amendment) | Arnold: Williams entered the home’s curtilage (under the carport) at 2:00 a.m. to investigate an open door — a trespassory, unreasonable search | Williams: He was investigating an open door and seeking to identify occupant; conduct did not constitute a search or was reasonable | Court: Reversed dismissal — complaint plausibly alleged a trespassory search of curtilage; remanded for district court to decide qualified immunity |
| Unreasonable seizure (Fourth Amendment) | Arnold: The officer’s demand for ID and attempt to grab him amounted to a seizure | Williams: No application of physical force and no submission to authority (Arnold fled), so no seizure occurred | Court: Affirmed dismissal — complaint did not plausibly allege a seizure under Hodari D./Brendlin standards |
| False arrest / false imprisonment (§ 1983) | Arnold: Arrest and detention were wrongful because there was no probable cause | Williams: Flight and trespass/supporting facts provided probable cause for arrest | Court: Affirmed dismissal — allegations too conclusory to negate probable cause and fail to plausibly plead false arrest/imprisonment |
| Malicious prosecution (§ 1983) | Arnold: Prosecuted without probable cause | Williams: No separate constitutional right to be free from malicious prosecution | Held: Affirmed dismissal — no freestanding malicious-prosecution claim under the Constitution; such facts are subsumed in Fourth Amendment claims |
| Due process (substantive & procedural) | Arnold: Due process rights violated by arrest/prosecution | Williams: Fourth Amendment provides the relevant protections; no independent due-process claim against state actor under Fifth Amendment | Court: Affirmed dismissal — Fourth Amendment is the proper vehicle; Fifth Amendment inapplicable; Fourteenth subsumed by Fourth claim |
| State torts: IIED and negligence | IIED: conduct was extreme and outrageous; Negligence: deputy breached duty in effecting arrest | Williams: Conduct not extreme; acted reasonably under circumstances | Court: Affirmed IIED dismissal for failure to allege extreme conduct; affirmed summary judgment on negligence — no genuine dispute that deputy acted reasonably |
Key Cases Cited
- Florida v. Jardines, 569 U.S. 1 (U.S. 2013) (physical intrusion onto curtilage is a Fourth Amendment search)
- United States v. Jones, 565 U.S. 400 (U.S. 2012) (physical intrusion test for searches)
- Katz v. United States, 389 U.S. 347 (U.S. 1967) (reasonable expectation of privacy framework)
- California v. Hodari D., 499 U.S. 621 (U.S. 1991) (seizure occurs by force or submission to show of authority)
- Brendlin v. California, 551 U.S. 249 (U.S. 2007) (passenger is seized when a vehicle stop occurs)
- Gomez v. Toledo, 446 U.S. 635 (U.S. 1980) (elements of a § 1983 claim)
- Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (plausibility pleading standard)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (U.S. 2007) (pleading must be plausible, not merely conceivable)
- Anderson v. Valdez, 845 F.3d 580 (5th Cir. 2016) (qualified-immunity pleading principles)
- Haggerty v. Tex. S. Univ., 391 F.3d 653 (5th Cir. 2004) (probable-cause requirement for false-arrest § 1983 claims)