submitted by Nick Ellis, Poyner Spruill
Caleb Wardrett v. City of Rocky Mount Police Department, Det. Clifton and Det. Denotter ( United States District Court for the Eastern District of North Carolina, 2016)
The federal court granted summary judgment for the City of Rocky Mount, its Police Department and detectives in a case brought against them under 42 USC §1983 where claims were asserted for malicious prosecution and false arrest. The police detectives conducted interviews of witnesses who had information concerning an attempted homicide that took place in Rocky Mount. As a result of that investigation, the plaintiff was charged with attempted murder. The detectives believed they had probable cause to have an arrest warrant issued. This belief was supported by the fact that the local magistrate found probable cause existed and issued the warrant. However, at a subsequent state court probable cause hearing, several witnesses failed to appear or changed their accounts of what happened, which led to the charges being dismissed.
Plaintiff then filed his civil suit in the United States District Court claiming violations under 42 USC §1983. Claims were made against the detectives in their official and individual capacities. The court analyzed these claims and determined the plaintiffs Fourth Amendment rights had not been violated. The court noted that a finding of probable cause defeats a false arrest/malicious prosecution claim. Probable cause is based on a practical assessment of the totality of the circumstances and the court found that the detectives had probable cause to seek the issuance of the arrest warrant based on the information they uncovered. In its analysis, the court focused on the critical point in time and looked at what the officers reasonably believed when the charges were issued-and not what occurred through later developments.
Plaintiff also stated a Monell claim against Rocky Mount under §1983. But, no claim can be recognized for respondeat superior liability under §1983. The trial court concluded there was no evidence of a policy in the Rocky Mount Police Department that was the basis of the constitutional violation in addition to its initial finding, which was no constitutional violation occurred. Based on the failure to demonstrate that his constitutional rights of been violated, the trial court dismissed plaintiffs case.