Steven Trainer v. Robert Anderson
663 F. App'x 241
| 3rd Cir. | 2016Background
- Pro se plaintiff Steven Trainer, a state prisoner, sued police officers under 42 U.S.C. § 1983 alleging false arrest (and conspiracy), excessive force, and unlawful seizure of a vehicle; the district court dismissed the false-arrest and vehicle-seizure claims for failure to state a claim and later granted summary judgment for defendants on excessive-force after discovery.
- Trainer sought leave to amend his false-arrest claim to allege the arrest warrant was supported by a “bare bones” affidavit; the district court denied amendment without addressing futility in detail.
- The arrest was made pursuant to a warrant based on a victim identification, the victim’s description, and the vehicle associated with the crime being parked outside Trainer’s home.
- Trainer contended that during arrest officers knocked him down with a car door, multiple officers jumped on and struck him, and he suffered facial abrasions and contusions; defendants disputed these facts, contending Trainer resisted and reached for his waistband.
- The district court credited the officers’ version at summary judgment (including that Trainer reached for his waistband) and entered judgment for defendants; Trainer appealed.
Issues
| Issue | Trainer's Argument | Defendants' Argument | Held |
|---|---|---|---|
| Validity of original false-arrest dismissal (warrant-based arrest) | Warrant not supported by probable cause; identification was weak | Reliance on warrant was reasonable given victim ID, description, and vehicle link | Affirmed: original complaint failed to state a claim against officers relying on the warrant |
| Leave to amend false-arrest claim to allege a “bare bones” affidavit | Amendment would allege affidavit lacked operative facts, so warrant is not protective | Amendment futile and merely rephrased original claim | Vacated & remanded: district court erred by not considering futility and other Foman factors before denying leave to amend |
| Summary judgment on excessive-force claim | Officers used unnecessary, severe force (knocked down, multiple strikes, ramming); injuries documented — disputed facts create triable issue | Force was reasonable because Trainer resisted and reached for his waistband; charges of resisting/arrest support officers' account | Vacated: genuine disputes of material fact exist and summary judgment was improper; qualified immunity premature |
| Failure-to-intervene liability for two detectives | They failed to intervene while colleagues used excessive force | Underlying excessive-force claim fails, so no liability | Vacated with excessive-force vacatur; remanded to consider intervention claims (no opinion on merits) |
Key Cases Cited
- Wilson v. Russo, 212 F.3d 781 (3d Cir. 2000) (officer liability where false statements or omissions in warrant application create falsehood)
- Messerschmidt v. Millender, 132 S. Ct. 1235 (2012) (warrant challenge where affidavit lacks indicia of probable cause can defeat official reliance)
- United States v. Leon, 468 U.S. 897 (1984) (good-faith exception to the exclusionary rule and circumstances when warrant reliance is unreasonable)
- Whiteley v. Warden, Wyo. State Penitentiary, 401 U.S. 560 (1971) (warrant unsupported by operative facts may be invalid)
- Foman v. Davis, 371 U.S. 178 (1962) (factors for granting leave to amend complaint)
- Graham v. Connor, 490 U.S. 386 (1989) (Fourth Amendment reasonableness standard for use of force)
- Santini v. Fuentes, 795 F.3d 410 (3d Cir. 2015) (factors to determine objective reasonableness of force)