May v. City of Nahunta, Georgia, No. 15-11749 (11th Cir. 2016)Annotate this Case
Plaintiff filed suit under 42 U.S.C. 1983, alleging unlawful seizure by Officers Allen and Crews, false imprisonment by Officer Allen, and municipal liability against the City for the officers' actions. The district court granted qualified immunity to Officer Allen with respect to plaintiff's federal and state claims. The district court also granted summary judgment to Officer Crews and the City. The court affirmed in part, reversed in part, and remanded. The court concluded that Officer Allen had arguable probable cause to seize plaintiff and found that the district court’s erroneous conclusion that the standard was not clearly established was harmless error. Accordingly, the court affirmed the district court's ultimate holding as to the propriety of Officer Allen’s initial decision to seize and transport plaintiff to the hospital. The court similarly concluded that Officer Allen is entitled to qualified immunity on plaintiff's 1983 false imprisonment claim. However, the court concluded that the district court erred in granting Officer Allen qualified immunity for his conduct during the seizure. Therefore, the court reversed and remanded on the question of whether Officer Allen’s conduct during the seizure was done in an extraordinary manner unusually harmful to plaintiff's privacy interests.