Loftin v. City of Prentiss, MS, No. 21-60611 (5th Cir. 2022)
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Officers of the Prentiss Police Department arrested Plaintiff for aggravated assault after he and others told the officers that Plaintiff had shot the victim. Plaintiff sued the officers and the City of Prentiss under 42 U.S.C. Section 1983 for arresting him without probable cause. He argued that the officers lacked probable cause because he told them that he shot the victim in self-defense. The district court granted summary judgment on all claims and awarded fees to the defendants.
On appeal, Plaintiff argued, first, that the Officer and Chief arrested him without probable cause and that they are not entitled to qualified immunity. Second, the Chief intentionally or recklessly omitted material statements in the warrant affidavit, resulting in a warrant lacking probable cause. Third, the City of Prentiss is liable under Monell. Fourth, he established a material fact issue on his state-law malicious-prosecution claim. Finally, Defendants are not entitled to attorneys’ fees.
The Fifth Circuit affirmed the district court’s summary judgment order and award of fees to Defendants. The court reasoned it is not enough to invoke the general principle that the Fourth Amendment prohibits a warrantless arrest without probable cause. Therefore, the Officer and Chief would be entitled to qualified immunity even if they lacked probable cause for the initial warrantless arrest. Further, the court concluded that Plaintiff cannot show want of probable cause therefore, his malicious-prosecution claim cannot succeed. Finally, Plainitff has not shown that the district court abused its discretion in granting attorneys’ fees.
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