Mara v. Rilling, No. 17-3326 (2d Cir. 2019)Annotate this Case
Defendants appealed the district court's order denying summary judgment based on qualified immunity in an action brought by plaintiff, alleging that defendants, police officers, violated the United States Constitution and Connecticut state law in investigating and arresting plaintiff for assaulting a guest at a college New Year's Eve party.
The Second Circuit reversed and held that defendants were entitled to qualified immunity as a matter of law. The court held that police did not need probable cause to arrest plaintiff because he was not under arrest when he was interviewed by the policy on January 2, 2013; there was probable cause to arrest plaintiff based on a non-defective eyewitness identification without regard to plaintiff's allegedly coerced statements; plaintiff's statements were not necessary to establish probable cause and thus he could not claim that their use was in violation of the Fifth Amendment; and the police procedures used at plaintiff's interview were not so egregious or shocking as to violate Fourteenth Amendment due process or to support a state claim for intentional infliction of emotional distress.