Miller, et al v. Stroman, et al, No. 20-50408 (5th Cir. 2022)
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In a consolidated appeal, Plaintiffs challenged the district court’s application of the independent intermediary doctrine to dismiss their Fourth Amendment false arrest claims. Plaintiffs are motorcyclists who had gathered at a meeting and were eventually arrested following a shootout for Engaging in Organized Criminal Activity (“EIOCA”). All were arrested pursuant to the same “form warrant affidavit” that was presented as the basis for the arrest warrants. Following their arrests, Plaintiffs filed multiple individual Sec. 1983 actions asserting similar false arrest claims, which were premised on alleged defects in the form affidavit used to secure the arrest warrants. The district court granted in full the motion to dismiss the false arrest claims, but it did not discuss the merits of the claims.
The Fifth Circuit reversed the district court’s ruling and found in favor of Plaintiffs in their challenge of the district court’s application of the independent intermediary doctrine to dismiss their Fourth Amendment false arrest claims. The court held that the district court erred in its application of the independent intermediary doctrine. The court reasoned that an adequately pled Malley or Franks claim will also suffice to functionally apply the taint exception to the magistrate’s decision, if a plaintiff adequately pleads that a second intermediary, such as a grand jury, has been misled in a similar fashion, then the taint exception will apply to that intermediary’s decision as well. The court declined to decide whether Plaintiffs have adequately pleaded a Franks violation with respect to any of the named defendants.
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