Sweat v. City of Las Cruces
676 F. App'x 780
| 10th Cir. | 2017Background
- On Sept. 14, 2012 Officer Baker observed a white Ford Mustang with a large horizontal crack in its windshield; she turned on lights to stop it but the driver (Sweat) briefly pulled over only to let her pass and then fled, prompting a ~2-minute pursuit and PIT maneuvers; Sweat was arrested and state charges were later dismissed with prejudice after a hung jury.
- Sweat sued under 42 U.S.C. § 1983 against Baker, other officers, the police chief, and the City, alleging the initial stop and ensuing chase violated his Fourth and Fourteenth Amendment rights and asserting municipal/supervisory liability and state-law claims.
- Defendants moved for summary judgment based on qualified immunity, arguing Baker had reasonable suspicion/probable cause because the cracked windshield gave rise to an equipment/unsafe-vehicle violation; magistrate judge initially recommended denying summary judgment as to the initial stop but granting it for the chase/arrest.
- After discovery produced dozens of photos showing a large horizontal windshield crack, the magistrate judge and district court concluded the crack was undisputed and would lead a reasonable officer to suspect a traffic/equipment violation under New Mexico law; they granted summary judgment for defendants on the Fourth Amendment stop claim and dismissed state claims without prejudice.
- Sweat appealed; the Tenth Circuit reviewed de novo and affirmed, holding the visible windshield crack gave Baker a reasonable articulable suspicion to initiate the stop and that Baker’s subjective motive (identity check) was irrelevant to the objective-reasonableness inquiry.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Legality of initial traffic stop | Sweat alleged no traffic/equipment violations were observed; his verified complaint denied any windshield crack and claimed stop was pretext to check identity | Baker observed a large horizontal crack that obscured view and gave reasonable suspicion of violating NM equipment/unsafe-vehicle laws | Burned: The visible crack (shown in photos) was undisputed and provided reasonable articulable suspicion; summary judgment for defendants affirmed |
| Effect of plaintiff’s verified allegations on summary judgment | Verified complaint/affidavit created factual dispute and credibility determination inappropriate at summary judgment | Photographic evidence and Baker’s sworn statements blatantly contradicted Sweat’s denial; no reasonable jury could credit Sweat | Held: Court may reject contradicted self-serving allegations; no genuine dispute remained |
| Relevance of officer’s subjective motive | Sweat argued Baker’s true motive was to check identity, making stop unconstitutional | Defendants: Objective standard controls; motive irrelevant if facts support reasonable suspicion | Held: Subjective motivations immaterial; objective facts govern and supported stop |
| Municipal/supervisory liability for training/supervision | Montoya/City liable for failing to intervene/train if individual officers violated rights | If no constitutional violation by officers, no supervisory or municipal liability | Held: Because no violation on stop, municipal/supervisory claims fail (and state claims dismissed without prejudice) |
Key Cases Cited
- Keith v. Koerner, 843 F.3d 833 (10th Cir. 2016) (standard of review for summary judgment affirmed)
- Gutierrez v. Cobos, 841 F.3d 895 (10th Cir. 2016) (view evidence in light most favorable to nonmoving party)
- Ribeau v. Katt, 681 F.3d 1190 (10th Cir. 2012) (same summary judgment principles)
- United States v. Winder, 557 F.3d 1129 (10th Cir. 2009) (traffic stop justified by reasonable articulable suspicion of traffic/equipment violation)
- United States v. Sanchez, 519 F.3d 1208 (10th Cir. 2008) (objective standard for evaluating officer conduct)
- United States v. DeGasso, 369 F.3d 1139 (10th Cir. 2004) (officer’s subjective motivations are irrelevant)
- Terry v. Ohio, 392 U.S. 1 (1968) (objective-reasonableness standard for seizures)
- Morales-Fernandez v. I.N.S., 418 F.3d 1116 (10th Cir. 2005) (failure to timely object to magistrate findings waives appellate review)
- United States v. Bazaldua, 506 F.3d 671 (8th Cir. 2007) (definition/explanation of PIT maneuver)