Salley v. Myers, No. 19-6374 (4th Cir. 2020)
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The Fourth Circuit vacated the district court's grant of summary judgment in favor of defendant in an action brought by plaintiff under 42 U.S.C. 1983, alleging a malicious prosecution claim. In this case, defendant arrested plaintiff and charged him with congregating on the sidewalk in violation of the City Code of Columbia, South Carolina. Defendant voluntarily dropped the charge over three years later. Plaintiff alleged that defendant arrested him without probable cause and ultimately dismissed the case because plaintiff was innocent.
The court held that there is a genuine dispute of material fact concerning the termination of criminal proceedings against plaintiff. Viewing the facts in the light most favorable to plaintiff, the court held that plaintiff has presented testimony that conflicts with defendant's explanation, as well as corroborating circumstantial evidence from which a jury could reasonably infer that the nolle prosse was consistent with plaintiff's innocence. Therefore, in light of the evidence and the fact that the district court cannot weigh credibility at this stage, summary judgment was not appropriate. The court remanded for further proceedings.
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