Uzoukwu v. City of New York, 704 F. App'x 32

Plaintiff Afam Uzoukwu was arrested in a New York City park for allegedly violating a park sign rule prohibiting persons without children from being in the children’s area; he sued under 42 U.S.C. § 1983 for false arrest.
At trial, officers testified Uzoukwu was alone, focused on eating Jell-O, not interacting with or supervising children, had no items suggesting he was with children, and did not identify any child when asked.
Officers observed no children approach during their interaction and Uzoukwu became disruptive when questioned.
A Customs and Border Protection agent testified there was no immigration record showing Uzoukwu’s children had entered the U.S. around the time he claimed, which undermined his account that children were present.
The jury returned a verdict for defendants; the district court denied Uzoukwu’s Rule 50(b) and Rule 59 motions and entered judgment for defendants.
On appeal, Uzoukwu argued (1) lack of probable cause as a matter of law and (2) improper admission of immigration-record testimony as unduly prejudicial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Probable cause for arrest under the park rule	Uzoukwu: officers lacked probable cause; judgment as a matter of law required	Defendants: officers had reasonably trustworthy facts to conclude Uzoukwu was in park without children	Affirmed — reasonable jurors could find probable cause based on officers' observations and conduct
Applicability of alternate grounds for arrest (disorderly conduct/obstruction)	Uzoukwu: probable cause lacking for any charged offense	Defendants: probable cause need only exist for any offense supported by facts	Court: unnecessary to decide because probable cause for park-rule violation sufficed
Admission of CBP agent testimony re: immigration records	Uzoukwu: testimony risked inflaming anti-immigrant bias; unduly prejudicial	Defendants: testimony was directly probative of Uzoukwu’s claim that his children were present	Affirmed — probative value outweighed potential prejudice; admission not an abuse of discretion
Standard of review for Rule 50(b)/Rule 59 motions	Uzoukwu: district court erred in denying motions	Defendants: jury verdict supported; review standards deferential where appropriate	Affirmed — de novo review for Rule 50(b); no legal insufficiency shown; Rule 59 denial not abused

Devenpeck v. Alford, 543 U.S. 146 (2004) (probable cause may be based on facts supporting a different offense than the one identified)
Escalera v. Lunn, 361 F.3d 737 (2d Cir. 2004) (definition of probable cause in arrest context)
Florida v. Harris, 568 U.S. 237 (2013) (probable cause assessed by whether there is a fair probability)
Figueroa v. Mazza, 825 F.3d 89 (2d Cir. 2016) (probable cause for any crime defeats false arrest claim)
Leopold v. Baccarat, Inc., 174 F.3d 261 (2d Cir. 1999) (evidence that provokes strong reactions can still be admissible if probative)
Crawford v. Tribeca Lending Corp., 815 F.3d 121 (2d Cir. 2016) (district court’s evidentiary rulings reviewed for abuse of discretion)
Yurman Design, Inc. v. PAJ, Inc., 262 F.3d 101 (2d Cir. 2001) (standard for judgment as a matter of law)