Trenisha Webster v. Jennifer Westlake, No. 21-1552 (8th Cir. 2022)
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Des Moines detectives arrested Plaintiff on her porch after she refused to comply with their requests to check on her daughter’s welfare. Plaintiff sued them under 42 U.S.C. Section 1983 and Iowa tort law. The district court granted summary judgment to Plaintiff on her Section 1983 claim and denied qualified immunity to the detectives.
Defendants appealed and the Eighth Circuit affirmed. The court explained state officials are entitled to qualified immunity in Section 1983 lawsuits unless they violated a federal “statutory or constitutional right that was clearly established at the time.” Here, because the detectives did not have arguable probable cause to arrest Plaintiff for interference with official acts, and they likewise didn’t have arguable or actual probable cause to arrest her for another offense, her Fourth Amendment right to be free from warrantless arrests under these circumstances was clearly established. And because the detectives subjected Plaintiff to a warrantless arrest that was unsupported by probable cause, they violated her clearly established rights. The detectives are not entitled to qualified immunity.
Court Description: [Kobes, Author, with Grasz and Stras, Circuit Judges] Civil case - Civil rights. Under Iowa law, the plaintiff did not interfere with the defendants' attempts to perform their official duties; the officers did not have a warrant, and they had no right to lawfully enter plaintiff's home without consent nor force her to take any specific action with respect to her minor daughter; plaintiff's refusal to cooperate with the officers' attempts to conduct a welfare check on the girl was not resistance or obstruction in violation of the Iowa statute; as such, the officers did not have probable cause to arrest plaintiff for interference with official acts; her arrest violated her clearly established Fourth Amendment rights, and the officers were not entitled to qualified immunity.
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