Tayvin Galanakis v. City of Newton, Iowa
134 F.4th 998
| 8th Cir. | 2025Background
- Tayvin Galanakis was stopped by Newton, Iowa police officers after midnight for driving with high beams; no erratic driving was observed.
- During the stop, officers noted multiple air fresheners in the car, gum chewing, and initial difficulty finding documents, but Galanakis completed field sobriety tests and two breathalyzer tests showed a 0.00 BAC.
- After Galanakis hesitated to consent to a further drug evaluation and said he wanted to go home, officers arrested him for operating while intoxicated (OWI) on suspicion of marijuana impairment.
- Subsequent drug evaluation at the station found no impairment, and Galanakis was released.
- Galanakis sued officers Winters and Wing under § 1983 for arrest without probable cause and related state-law claims; the district court denied the officers’ motions for qualified and statutory immunity.
- The officers appealed the denial of immunity and the related claims against the city.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Qualified immunity for arrest without probable cause (Fourth Amendment) | Officers lacked even arguable probable cause for DUI arrest; no signs of impairment | Officers had arguable probable cause based on totality of circumstances | Denied qualified immunity; no arguable probable cause existed |
| State-law statutory immunity (Iowa Code) | State immunity tracks federal qualified immunity; officers' conduct unreasonable | Argued a good faith, reasonable belief based on circumstances sufficed | Court declined jurisdiction; did not resolve state-law immunity |
| Summary judgment for City under respondeat superior | City liable for officers’ actions if underlying arrest lacks probable cause | City not liable because officers entitled to immunity | Court declined jurisdiction as to city/state-law claims |
Key Cases Cited
- Scott v. Harris, 550 U.S. 372 (objective evidence, like video, can override witness accounts regarding the facts of an incident)
- Anderson v. Creighton, 483 U.S. 635 (qualified immunity requires a clearly established right such that a reasonable officer would understand conduct violates that right)
- District of Columbia v. Wesby, 583 U.S. 48 (probable cause is judged by totality of the circumstances as seen by the objectively reasonable officer)
- Miranda v. Arizona, 384 U.S. 436 (Miranda rights must be read before custodial interrogation)
- Devenpeck v. Alford, 543 U.S. 146 (probable cause for arrest is objective, not based on officers' subjective intent)
- Illinois v. Wardlow, 528 U.S. 119 (evasive behavior may contribute to probable cause assessment)
- Maryland v. Pringle, 540 U.S. 366 (probable cause requires a reasonable belief of a substantial chance of criminal activity)