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Slip Opinion
D.N.M.
Apr 19, 2013
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Background

  • Plaintiff Charles White sues Detective Brian Sanchez under 42 U.S.C. § 1983 for malicious prosecution.
  • Albuquerque police investigated September 2006 after infant D.W. stopped breathing; White was charged but acquitted.
  • Plaintiff previously filed state-law malicious abuse of process claim which was dismissed on statute-of-limitations grounds.
  • Sanchez moved for summary judgment arguing qualified immunity and probable cause for arrest.
  • Disputes centered on whether statements White made during interrogation were truthful or coerced, and whether the warrant affidavit omitted exculpatory medical evidence.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether White's interview statements were voluntary Statements were coerced by misrepresentations. Statements were voluntary and not coercive. Statements were voluntary; no coercion found.
Whether the grand jury indictment was misled by Sanchez's statements Grand jury relied on inaccurate portrayal of White's statements. Overstatement occurred but did not mislead; probable cause remains. No reasonable juror would find the grand jury misled; probable cause supported.
Whether the arrest warrant affidavit misrepresented medical evidence or omitted exculpatory evidence Sanchez misrepresented medical findings, undermining probable cause. Medical evidence supported probable cause; no material omissions. Affidavit did not misrepresent or omit information to defeat probable cause.
Whether there was probable cause for White's arrest and prosecution A preexisting medical evidence undermines causation. A substantial probability of crime existed; age of injuries immaterial. Probable cause existed; qualified immunity applies and summary judgment granted.

Key Cases Cited

  • Novitsky v. City of Aurora, 491 F.3d 1244 (10th Cir. 2007) (elements of §1983 malicious prosecution claim)
  • Wilkins v. DeReyes, 528 F.3d 790 (10th Cir. 2008) (arrest warrant triggers §1983 liability; probable cause standard)
  • Pierce v. Gilchrist, 359 F.3d 1279 (10th Cir. 2004) (probable cause factors and initiation of legal process)
  • Grubbs v. Bailes, 445 F.3d 275 (10th Cir. 2006) (probable cause analysis and First Amendment/false arrest standards)
  • Texas v. Brown, 460 U.S. 730 (1983) (probable cause requires substantial probability of crime and involvement by individual)
  • Armijo v. Wagon Mound Pub. Schs., 159 F.3d 1253 (10th Cir. 1998) (clear-right standard for qualified immunity parameters)
  • Prager v. LaFaver, 180 F.3d 1185 (10th Cir. 1999) (clearly established law for qualified immunity analysis)
  • St. John v. Justman, 771 F.2d 445 (10th Cir. 1985) (probable cause and reasonable basis standard)
  • United States v. Erving L., 147 F.3d 1240 (10th Cir. 1998) (coercion and voluntariness of statements standard)
  • Rex v. Teeples, 753 F.2d 840 (10th Cir. 1985) (coercive interrogation and due process considerations)
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Case Details

Case Name: White v. Sanchez
Court Name: District Court, D. New Mexico
Date Published: Apr 19, 2013
Citation: 1:12-cv-00517
Docket Number: 1:12-cv-00517
Court Abbreviation: D.N.M.
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