Williams v. Aguirre, No. 19-11941 (11th Cir. 2020)
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Plaintiff filed suit against two officers, alleging claims of malicious prosecution under both the Fourth Amendment and Alabama law. After plaintiff was shot by one of the officers and spent two months in a hospital recovering, he spent more than 16 months in pretrial detention on charges of attempted murder. The charges were eventually dropped when a news organization eventually published a video recorded on a dashboard camera that supported plaintiff's account that he had dropped his gun and complied with the officers' commands.
The Eleventh Circuit affirmed the district court's denial of summary judgment based on qualified immunity to the officers. The court held that the record presents a genuine dispute of fact about whether plaintiff's pretrial detention was unlawful where, regardless of its applicability to warrantless arrests, the any-crime rule does not apply to claims of malicious prosecution under the Fourth Amendment; malicious prosecution requires plaintiff to prove that the judicial determination of probable cause underlying his seizure was invalid; and plaintiff has established a genuine issue of fact over whether he suffered an unconstitutional seizure pursuant to legal process. Furthermore, the officers caused plaintiff's injury and plaintiff had a clearly established right to not be seized based on intentional and material misrepresentations in a warrant application. The court also held that the officers are not entitled to state-agent immunity because a genuine dispute of fact exists about whether the officers acted maliciously.
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