Mayfield v. Currie, No. 19-60331 (5th Cir. 2020)
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The Fifth Circuit reversed the district court's denial of Officer Currie's motion to dismiss based on qualified immunity. Plaintiffs filed suit under 42 U.S.C. 1983 and 1988, alleging constitutional violations after Mark Mayfield committed suicide. The Madison Police Department had arrested Mark and two conspirators, and the basis for the arrest warrant was the affidavit of Currie, who stated that Mark had communicated with conspirators and assisted them in their effort to photograph the wife of United States Senator Thad Cochran in an assisted living facility. Currie claims that there was no constitutional violation because the issuance of the arrest warrant broke the causal chain, immunizing her from liability.
The court held that there are two ways to overcome the independent-intermediary doctrine: first, in Malley v. Briggs, 475 U.S. 335, 344–45 (1986), the Supreme Court held that an officer can be held liable for a search authorized by a warrant when the affidavit presented to the magistrate was so lacking in indicia of probable cause as to render official belief in its existence unreasonable; and second, under Franks v. Delaware, 438 U.S. 154 (1978), and its progeny, officers who deliberately or recklessly provide false, material information for use in an affidavit or who make knowing and intentional omissions that result in a warrant being issued without probable cause may still be held liable.
The court held that, under Malley, the information Currie and other investigators provided to the magistrate throughout the course of their investigation clearly was sufficient to establish probable cause to issue a warrant for Mark's arrest. Therefore, the district court erred in concluding that plaintiffs adequately alleged wrongdoing under Malley. The court remanded to the district court for further consideration of Franks.
The court issued a subsequent related opinion or order on September 23, 2020.
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