Trafton v. City of Woodbury
2011 U.S. Dist. LEXIS 70682
| D.N.J. | 2011Background
- On July 5, 2007, Trafton deposited film at CVS in Woodbury; photos showed minors with weapons, including a crossbow.
- CVS staff notified Woodbury police; Holmstrom, not initially involved, was later dispatched to CVS.
- Holmstrom questioned Trafton about the photographs and made hostile, accusatory remarks.
- Trafton refused to provide her name; Holmstrom told her she would be arrested for hindrance and she allegedly resisted.
- A struggle occurred, Trafton was handcuffed, transported to the police station, and detained; she was charged with multiple offenses.
- Trafton pled guilty to obstruction; she filed this federal civil rights action alleging false arrest, seizure, excessive force, and NJCRA/ state-law claims; Defendants moved for summary judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the CVS encounter constituted an unlawful seizure under the Fourth Amendment | Trafton was not free to leave; seizure occurred | No seizure; questioning is permissible | The encounter amounted to a seizure but was supported by reasonable suspicion for a brief detention |
| Whether Holmstrom had probable cause for Trafton's initial arrest for hindrance | Arrest without probable cause | Probable cause existed for hindrance based on refusals to identify and attempt to leave | Summary judgment on probable cause denied; factual dispute precludes ruling on qualified immunity at this stage |
| NJCRA claims versus §1983 claims | NJCRA mirrors §1983 and should be analyzed similarly | NJCRA analyzed analogously to §1983; some claims fail for lack of constitutional violation | NJCRA claims analyzed on §1983 framework; some claims barred against Woodbury entities, but some survive against Holmstrom |
| Excessive force and related common-law claims | Handcuffing and handling caused permanent wrist injury; excessive force | Handcuffing reasonable given resistance; genuine disputes exist about post-arrival treatment | Excessive force claim survives against Holmstrom to the extent asserted; pre-arrival conduct summary-judgment appropriate; summary judgment denied for post-arrival handling depending on facts |
Key Cases Cited
- McTernan v. City of York, Pa., 564 F.3d 636 (3d Cir.2009) (establishes policy vs. custom for municipal liability; deliberate indifference required)
- Beck v. City of Pittsburgh, 89 F.3d 966 (3d Cir.1996) (Monell policy/custom framework for §1983 liability)
- Groman v. Twp. of Manalapan, 47 F.3d 628 (3d Cir.1995) (deliberate indifference standard for failure-to-train/supervise)
- Tobin v. Badamo, 78 Fed. Appx. 217 (3d Cir.2003) (supervisory liability for deliberate indifference; summary judgment analysis)
- Pearson v. Callahan, 555 U.S. 223 (2009) (qualified immunity two-step framework)