Saterdalen v. Spencer, et al., No. 12-2953 (8th Cir. 2013)
Annotate this CasePlaintiff filed suit under 42 U.S.C. 1983, alleging that a detective submitted a false statement of probable cause to secure a warrant for his arrest and that an assistant county attorney approved the warrant application even though it lacked probable cause. The detective sought a warrant for plaintiff's arrest, alleging that he had knowingly violated the state registration requirements for predatory offenders or intentionally provided false information. In light of the facts known to the detective when he applied for the warrant and the ambiguity of the statutory language, the court could not say that no reasonably competent officer would have applied for an arrest warrant. Accordingly, the court concluded that the detective was entitled to qualified immunity where the belief that probable cause existed to arrest plaintiff for failing to register his Belize address as his primary address - even if that belief was mistaken - was objectively reasonable. Even if no probable cause existed to support the warrant for plaintiff's arrest, the attorney was nonetheless entitled to absolute immunity because his acts in reviewing and approving the complaint against plaintiff were taken to initiate the criminal prosecution. Accordingly, the court affirmed the judgment.
Court Description: Civil case - Civil rights. In light of the facts known to the police officer who sought a warrant for plaintiff's arrest for failure to comply with the reporting requirements of Minnesota's predatory offender statute, and in light of the ambiguity in the statute's language, the court could not say that no reasonably competent officer would have applied for an arrest warrant; as a result, the officer was entitled to qualified immunity on plaintiff's civil rights claims arising out of his arrest, extradition and detention; prosecuting attorney was entitled to absolute immunity for his acts in reviewing and approving the criminal complaint against plaintiff.
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