White v. Gilbert
4:24-cv-00136
W.D. Ky.Apr 14, 2025Background
- Jessie Lee White, a pretrial detainee at Daviess County Detention Center, filed a pro se § 1983 civil rights complaint against Detective Chad Gilbert and Prosecutor Michael Van Meter.
- White alleged false arrest after being pulled over for expired tags, with police discovering a hoodie linked to a previous crime; he was then charged with four counts of third-degree burglary.
- White claimed his prior criminal history was improperly used as probable cause for his arrest.
- The complaint sought compensatory and punitive damages, plus injunctive relief in the form of dismissal of charges and release on parole.
- The Court conducted an initial screening under 28 U.S.C. § 1915A and considered official and individual capacity claims against both defendants, as well as the availability of injunctive relief under § 1983.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| False arrest by Gilbert | Detected stopped and arrested him without valid probable cause | Charges based on criminal history, no policy or custom alleged | Dismissed; no allegation of wrongdoing or policy/custom for liability |
| Official-capacity claim vs. Gilbert | Municipal liability for actions of Detective | City liable only if policy/custom caused harm | Dismissed; no municipal policy/custom pled |
| Claims against Prosecutor Van Meter | Prosecutor improperly used criminal history as probable cause | Prosecutor immune for actions as advocate | Dismissed; absolute prosecutorial immunity applies |
| Injunctive relief (release, dismissal of charges) | Sought release and charge dismissal as part of § 1983 action | Such relief not available under § 1983; habeas is the exclusive remedy | Dismissed; not cognizable under § 1983 |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (sets the pleading standard for § 1983 complaints)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (complaints require more than conclusory statements)
- Kentucky v. Graham, 473 U.S. 159 (1985) (explains official-capacity claims)
- Monell v. New York City Dep't of Soc. Servs., 436 U.S. 658 (1978) (municipal liability under § 1983 requires policy or custom)
- Imbler v. Pachtman, 424 U.S. 409 (1976) (absolute prosecutorial immunity for acts as advocate)
- Preiser v. Rodriguez, 411 U.S. 475 (1973) (habeas corpus is exclusive remedy for challenging fact or duration of confinement)