Vickson Korlewala v. Dennis Slobodian
712 F. App'x 148
3rd Cir.2017Background
- Vickson and Lorpu Korlewala sued five Philadelphia detectives under 42 U.S.C. § 1983 after arrest warrants were issued based on Detective Hunt’s affidavit, alleging false arrest and a conspiracy to violate their Fourth Amendment rights.
- Count II (false arrest) named only Detectives Slobodian and Campbell, alleging Hunt’s probable-cause affidavit contained three inaccurate assertions and one omission that were knowingly false or made with reckless disregard for the truth.
- The District Court found one of Hunt’s statements showed reckless disregard, reconstructed the affidavit with corrected facts, and concluded the corrected affidavit still established probable cause; thus no Fourth Amendment violation.
- The District Court additionally granted summary judgment to Slobodian and Campbell on the independent ground that plaintiffs produced no evidence of those detectives’ personal involvement in the asserted wrongdoing.
- Count III (conspiracy) named all five detectives; the District Court found no evidence of an agreement among detectives to violate the Korlewalas’ constitutional rights and alternatively concluded the conspiracy claim failed because the underlying § 1983 claim lacked merit.
- The Korlewalas appealed; they did not challenge the District Court’s personal-involvement finding for Slobodian and Campbell on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Slobodian and Campbell are liable for false arrest based on Hunt’s affidavit inaccuracies | Hunt’s affidavit contained knowing or recklessly false statements and omissions that vitiate probable cause | Even after correcting inaccuracies, the affidavit establishes probable cause; also Slobodian and Campbell lacked personal involvement | Affirmed: plaintiffs forfeited challenge to personal-involvement finding; corrected affidavit still showed probable cause, so no false-arrest liability |
| Whether all five detectives can be liable for conspiracy to violate Fourth Amendment | Detectives coordinated (e.g., exchanged notes/photos) evidencing an agreement to deprive rights | Plaintiffs produced no evidence of a meeting of the minds; conspiracy requires an agreement; underlying § 1983 claim fails | Affirmed: no evidence of agreement; conspiracy claim fails (and fails alternatively because underlying claim lacks merit) |
Key Cases Cited
- Wilson v. Russo, 212 F.3d 781 (3d Cir. 2000) (framework for evaluating material falsehoods in probable-cause affidavits)
- Dempsey v. Bucknell Univ., 834 F.3d 457 (3d Cir. 2016) (applying false-statement/reckless-disregard analysis to probable-cause affidavits)
- Rode v. Dellarciprete, 845 F.2d 1195 (3d Cir. 1988) (personal involvement requirement for § 1983 liability)
- Startzell v. City of Philadelphia, 533 F.3d 183 (3d Cir. 2008) (conspiracy liability requires a meeting of the minds)
- Adickes v. S.H. Kress & Co., 398 U.S. 144 (1970) (agreement element in civil conspiracy claims)
- Trap Rock Indus. v. Local 825, Int’l Union of Operating Eng’rs, 982 F.2d 884 (3d Cir. 1992) (pleadings and briefs insufficient to defeat summary judgment without supporting evidence)