Fagnan v. City of Lino Lakes, et al., No. 12-4038 (8th Cir. 2014)
Annotate this CasePlaintiff, after being acquitted of state law charges related to the possession of firearms, filed suit against the City and eight police officers, under 42 U.S.C. 1983. On appeal, plaintiff challenged the district court's grant of summary judgment for the officers on his Fourth Amendment claim against them in their individual capacities. The court concluded that the officers did not exceed the scope of plaintiff's consent for them to be in the basement of his home where the officers had to walk through the basement to access another room; the warrant was supported by probable cause where the officers noticed two sawed off shotguns; the record did not reflect the deliberate falsehood or reckless disregard for the truth that violated the Fourth Amendment; and the officers had probable cause to arrest him on the state gun charges. Accordingly, the court affirmed the district court's judgment.
Court Description: Civil case - Civil rights. The district court did not err in granting defendants' motion for summary judgment based on qualified immunity as the defendants did not violate defendant's constitutional rights when they saw illegal sawed-off weapons as defendant had invited the officers into the area of his home where the officers saw the guns and they were in plain view; officers' action in obtaining a search warrant to seize the weapons was supported by probable cause; arrest incident to the search was supported by probable cause.
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