Williams v. City of New York, 683 F. App'x 57

Tamata Williams sued the City of New York and several officers (City Defendants) and obtained a default judgment against two private defendants (estranged husband Alphonso Williams and his mother Naomi Hull) who allegedly made false accusations.
Williams alleges she was arrested three times based on Hull’s complaints, which she contends were false and motivated by animosity.
The City Defendants moved for summary judgment arguing the arrests were supported by probable (or at least arguable probable) cause.
The District Court granted summary judgment for the City Defendants, concluding probable cause (or arguable probable cause) existed for each arrest and dismissing malicious prosecution claims for lack of actual malice.
Williams appealed; the Second Circuit reviewed de novo and affirmed the District Court’s judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
False arrest: whether probable cause existed for the three arrests	Hull’s complaints were false and motivated by vendetta; arrests were unlawful	Officers had reasonably trustworthy information (victim complaints/statements) supporting arrest; any animosity did not negate probable cause	Affirmed: probable cause or at least arguable probable cause existed
Qualified immunity for officers	Officers should not get immunity because arrests were based on false accusations	Officers entitled to qualified immunity if arguable probable cause existed	Affirmed: arguable probable cause satisfied qualified immunity standard
Malicious prosecution: whether prosecution was instituted with actual malice	Charges were brought maliciously based on false accusations	Probable cause supported charging decisions; no evidence City acted with actual malice	Affirmed: no actual malice; probable cause defeated malicious prosecution claim
Sufficiency of investigation before arrest	Officers failed to investigate plaintiff’s side and relied improperly on Hull	Officers may rely on victim complaints and were not required to disprove plaintiff before arrest	Affirmed: thoroughness concern does not defeat probable or arguable probable cause

Garcia v. Hartford Police Dep’t, 706 F.3d 120 (2d Cir. 2013) (standard of review for summary judgment)
Hicks v. Baines, 593 F.3d 159 (2d Cir. 2010) (conclusory allegations cannot defeat summary judgment)
Fletcher v. Atex, Inc., 68 F.3d 1451 (2d Cir. 1995) (same)
Weyant v. Okst, 101 F.3d 845 (2d Cir. 1996) (probable cause is a complete defense to false arrest)
Jenkins v. City of N.Y., 478 F.3d 76 (2d Cir. 2007) (definition of probable cause)
Singer v. Fulton Cty. Sheriff, 63 F.3d 110 (2d Cir. 1995) (victim complaint supporting arrest absent reasons to doubt veracity)
Curley v. Vill. of Suffern, 268 F.3d 65 (2d Cir. 2001) (officers need not prove plaintiff’s version wrong before arrest)
Escalera v. Lunn, 361 F.3d 737 (2d Cir. 2004) (arguable probable cause and qualified immunity standard)
Golino v. City of New Haven, 950 F.2d 864 (2d Cir. 1991) (officers of reasonable competence may disagree on probable cause)
Caldarola v. Calabrese, 298 F.3d 156 (2d Cir. 2002) (officer reasonably but mistakenly concluding probable cause supports qualified immunity)
Bermudez v. City of N.Y., 790 F.3d 368 (2d Cir. 2015) (malicious prosecution requires showing actual malice)