Van Aelstyn v. Sparks, 5:23-cv-00136

Michael Van Aelstyn sued Officer Sparks and Sergeant Carnes of the Versailles Police Department, alleging false arrest, malicious prosecution, and equal protection violations after a domestic incident with his fiancée, Stephanie Gibbon.
The incident involved conflicting accounts: Gibbon accused Van Aelstyn of assault and strangulation, while Van Aelstyn claimed Gibbon attacked him and fabricated allegations out of anger over suspected infidelity.
Police investigated by interviewing both parties and Gibbon’s daughter, observing physical injuries, and collecting statements. Van Aelstyn later provided an audio recording of the altercation.
Van Aelstyn was arrested and prosecuted for assault and strangulation, but the grand jury declined to indict after considering his recording.
Van Aelstyn then brought federal and state claims for false arrest, malicious prosecution, and violation of equal protection under 42 U.S.C. § 1983.
The court considers defendants’ motion for summary judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
False Arrest	Arrest without probable cause, claim accrues upon grand jury's no bill.	Probable cause existed, claim barred by 1-year statute—accrues at arrest date.	For defendants; claim time-barred under Kentucky’s SOL.
Malicious Prosecution	No probable cause and police ignored exculpatory evidence and inconsistencies in accuser's statements.	Probable cause existed based on injuries and statements; no exculpatory evidence withheld.	For defendants; probable cause existed, so no malicious prosecution.
Qualified Immunity	Clearly established right violated due to wrongful prosecution despite lack of probable cause.	No clearly established violation; no case shows rights violated under similar facts.	For defendants; qualified immunity applies.
Equal Protection	Intentionally treated differently from accuser without rational basis (class of one claim).	Rational basis: greater injury and physicality justified investigation focus on plaintiff.	For defendants; rational basis for differential treatment.

Wallace v. Kato, 549 U.S. 384 (statute of limitations for false arrest under §1983 runs from date of arrest)
Sykes v. Anderson, 625 F.3d 294 (probable cause required for malicious prosecution under §1983)
District of Columbia v. Wesby, 583 U.S. 48 (qualified immunity and probable cause standards)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment standard)
Brady v. Maryland, 373 U.S. 83 (obligation to disclose material exculpatory evidence)