Quinn v. Young, No. 13-2074 (10th Cir. 2015)
Annotate this CasePlaintiffs John Quinn and Lavern Gonzalez were arrested in connection with an Albuquerque Police Department (APD) larceny sting. They subsequently filed a civil-rights lawsuit against the arresting officers, William Young and Benjamin Melendrez, alleging: (1) a warrantless arrest without probable cause in violation of the Fourth Amendment; (2) entrapment; (3) substantive due process; and (4) malicious prosecution. The Officers moved for summary judgment based on qualified immunity, but the district court denied their motion. The district court concluded that a reasonable jury could have found that the Officers arrested Quinn and Gonzalez without probable cause. Additionally, the court determined that a reasonable law-enforcement official in the Officers’ position would have known it was unlawful to make the challenged arrests without probable cause that Quinn and Gonzalez possessed the requisite mens rea for the crime of larceny. In an interlocutory appeal of the denial of qualified immunity, the Officers argued the district court erred because they had probable cause to arrest Plaintiffs and, alternatively, because the law did not clearly establish that their actions during the sting violated the Fourth Amendment. The Tenth Circuit agreed with the Officers that the extant clearly established law would not have put a reasonable, similarly situated officer on notice that his conduct was unlawful. Therefore, the Court reversed the district court's decision on their motion for summary judgment based on qualified immunity grounds. The Court also dismissed Plaintiffs’ entrapment claim. Lastly, the Court remanded the case to the district court with instructions to explicitly set forth its reasoning as to whether the Officers could avail themselves of qualified immunity on Plaintiffs’ malicious-prosecution and substantive due process claims and to rule on those claims anew.
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