Guan v. City of New York, No. 20-4002 (2d Cir. 2022)
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Following a disturbance at a hospital, two New York City police officers arrested Plaintiff and transported her to another hospital for a psychiatric evaluation. Plaintiff asserted false arrest claims, alleging that the police officers lacked probable cause to arrest her for a mental health examination. The district court granted Defendants’ motion for summary judgment, holding that because the police officers had probable cause to arrest Plaintiff for a misdemeanor trespass, her false arrest claim was precluded. The district court did not reach the issue of the existence of probable cause for a mental health arrest. The district court also held, in the alternative, that the officers were protected by qualified immunity because they had arguable probable cause to make a mental health arrest.
The Second Circuit affirmed, concluding that while the district court erred in its probable cause analysis, the officers were protected by qualified immunity. The court explained that even where actual probable cause does not exist, police officers may be entitled to qualified immunity from a Section 1983 false arrest claim if their actions did not violate "clearly established" rights or if "arguable probable cause" existed at the time of the arrest.
Here, the parties disagree as to whether the officers had probable cause to arrest her for an emergency mental health evaluation. The court held that the existence of probable cause to arrest an individual for a criminal violation does not preclude a false arrest claim based on a wrongful arrest for a mental health evaluation. However, nonetheless, the officers here are protected by qualified immunity.
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