Tyree Bell v. Officer Peter Neukirch, 979 F.3d 594

911 caller reported two black juvenile males brandishing guns; officers encountered one who tossed a gun and fled; officer Munyan broadcast a BOLO describing a "juvenile black male, 17–18, about 5'10", skinny, blue shorts, white t-shirt, shoulder-length dreads."
Seven minutes later, about a mile away, Officer Viesselman stopped Tyree Bell (6'3") who was wearing a white t-shirt, black shorts with wide white stripes, short black socks, and black/red Nike shoes; Bell appeared only slightly sweaty and was breathing normally.
Officer Munyan arrived, identified Bell as the fleeing suspect, and officers reviewed dashcam footage multiple times; Bell was placed on an investigative hold, taken to the Juvenile Justice Center, and detained.
Two days later a juvenile court found probable cause to detain Bell; Bell remained detained for three weeks.
Detective Mattivi reviewed the patrol-car video three weeks after the arrest, concluded Bell was not the suspect (noting different shorts/socks), charges were dropped, and Bell was released.
Bell sued under 42 U.S.C. § 1983 alleging arrest without probable cause; the district court granted qualified immunity to the arresting officers, but the Eighth Circuit majority reversed as to those officers and affirmed dismissal of claims against the detective, sergeant, and municipal defendants.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Probable cause to arrest Bell	Bell: no probable cause — video and live observations showed substantial mismatches (height, hair, shorts, socks, shoes, demeanor)	Officers: probable cause existed — generic match (race, sex, age/juvenile), officer Munyan positively identified him and suspected shedding of outer clothing during flight	Court: No probable cause as a matter for jury — differences were plainly exculpatory and outweighed the generic matches; arrest violated Fourth Amendment; summary judgment for officers reversed
Qualified immunity for arresting officers	Bell: right clearly established; no reasonable officer could justify arrest given the obvious discrepancies	Officers: arguable probable cause; no controlling precedent showing violation under similar facts	Court: No qualified immunity — this was an "obvious case" where existing law (do not ignore plainly exculpatory evidence; investigate reasonably) put officers on notice their conduct was unlawful
Liability of detective, sergeant, and municipal defendants	Bell: supervisory/official-capacity liability for failures to train/supervise	Defendants: relied reasonably on officers' representations and video review; no municipal policy or pattern shown	Court: Affirmed summary judgment for detective, sergeant (individual capacity), police chief, and Board (official-capacity) — reasonable reliance and insufficient evidence of a municipal policy or deliberate indifference

Devenpeck v. Alford, 543 U.S. 146 (probable-cause standard for warrantless arrests)
Gerstein v. Pugh, 420 U.S. 103 (probable cause required for pretrial detention)
Brinegar v. United States, 338 U.S. 160 (probable cause protects against rash seizures; reasonable mistakes allowed)
Hill v. California, 401 U.S. 797 (arrest of innocent person permissible if officer reasonably believed probable cause existed)
Kuehl v. Burtis, 173 F.3d 646 (8th Cir. 1999) (officers must consider plainly exculpatory evidence and reasonably investigate)
Baptiste v. J.C. Penney Co., 147 F.3d 1252 (10th Cir. 1998) (watching surveillance that shows no crime undercuts probable cause)
District of Columbia v. Wesby, 138 S. Ct. 577 (qualified immunity; need for clearly established law; rare "obvious case")
Anderson v. Creighton, 483 U.S. 635 (qualified immunity standard: objectively reasonable mistake of law)
Harlow v. Fitzgerald, 457 U.S. 800 (objective standard for qualified immunity)
White v. Pauly, 137 S. Ct. 548 (plaintiff must identify similar-case precedent to show law was clearly established)