562 F. App'x 58
2d Cir.2014Background
- Thomas appeals a summary-judgment dismissal of his §1983 false arrest and malicious-prosecution claims against the City of New York and Detective Rodriguez.
- The district court held there was probable cause to arrest Thomas for the August 14, 2009 shooting of Jason Price.
- Evidence cited included Price’s close-range shooting, Price’s photo array identification of Thomas, and Price’s statement seeing Thomas near the scene after the gunfire.
- Thomas argues the arrest lacked probable cause and that more investigation was required before arrest.
- The Court of Appeals reviews de novo the existence of probable cause and affirms the district court.
- The court also rejects Thomas’s Monell claim against NYC, as underlying constitutional deprivation is not alleged.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was there probable cause to arrest Thomas? | Thomas asserts lack of probable cause. | Rodriguez contends sufficient factors supported probable cause. | Yes; probable cause existed. |
| Does probable cause to arrest defeat a later malicious-prosecution claim? | Thomas argues ongoing facts post-arrest undermine malicious-prosecution claim. | Rodriguez argues probable cause to arrest bars malicious-prosecution claim where no intervening facts dissipate it. | Yes; probable cause defeats malicious prosecution. |
| Does the record support a Monell claim against NYC? | Thomas challenges municipal liability for arrest decisions. | NYC contends no underlying constitutional deprivation is shown. | No; Monell claim fails. |
Key Cases Cited
- Walczyk v. Rio, 496 F.3d 139 (2d Cir. 2007) (probable cause requires knowledge or trustworthy information for a fair belief)
- Illinois v. Gates, 462 U.S. 213 (Supreme Court 1983) (probable cause is a practical, common-sense standard)
- Florida v. Harris, 133 S. Ct. 1050 (S. Ct. 2013) (probable cause is practical and all-things-considered)
- Panetta v. Crowley, 460 F.3d 388 (2d Cir. 2006) (information from eyewitness can establish probable cause)
- Caldarola v. Calabrese, 298 F.3d 156 (2d Cir. 2002) (arrest does not require disproving plaintiff's version before acting)
- Curley v. Village of Suffern, 268 F.3d 65 (2d Cir. 2001) (arresting officers not required to prove plaintiff wrong before arrest)
- Jenkins v. City of New York, 478 F.3d 76 (2d Cir. 2007) (probable cause as complete defense to false arrest and imprisonment)
- Manganiello v. City of New York, 612 F.3d 149 (2d Cir. 2010) (probable cause defeats malicious-prosecution claims)
- Lowth v. Town of Cheektowaga, 82 F.3d 563 (2d Cir. 1996) (dissipation of probable cause requires intervening facts)
- Zalaski v. City of Hartford, 723 F.3d 382 (2d Cir. 2013) (good-faith belief need not be correct or true)