Rodgers v. Knight, No. 14-1425 (8th Cir. 2015)
Annotate this CaseThe Eighth Circuit consolidated appeals from district court decisions granting defendants summary judgment in cases under 42 U.S.C. 1983 against law enforcement officials and municipalities. The claims related to the seizure of firearms, which were kept by the police for up to two years, and the arrests and prosecutions of plaintiffs, as to whom charges were ultimately dismissed. The Eighth Circuit affirmed, finding that there was a reasonable basis for retention of the firearms in both cases and that officers were entitled to qualified immunity for their actions in connection with the arrests and searches.
Court Description: Civil case - Civil rights. Prosecutors had absolute immunity for filing a criminal charge against plaintiff Greg Rodgers and the officers were entitled to qualified immunity for recommending an unlawful use of weapons charge; officers were entitled to qualified immunity on charge they violated plaintiff's rights by seeking a search warrant; search was reasonable and officers were entitled to qualified immunity for the scope of the search; officers were entitled to hold the weapons as evidence and returned them within a reasonable time after the close of the criminal proceedings; plaintiffs' Second Amendment claims were correctly dismissed as lawful seizure and retention of weapons does not violate the Second Amendment; officers were entitled to qualified immunity on claim they seized the weapons in retaliation for plaintiff's exercise of his First Amendment rights since they had probable cause to arrest plaintiff and seize his weapons; failure to train and instruct claims against the City of Columbia and Boone County rejected; claim that a senior judge cannot preside over the case is foreclosed by Eighth Circuit precedent, and claim the judge should have recused was raised for the first time on appeal and would not be considered. With respect to plaintiff Franklin's appeal, the officers had probable cause to seek a warrant and arrest him and were entitled to qualified immunity; guns seen in plain view during the execution of a "drug warrant" could be seized as tools of the drug trade and evidence of the offense; weapons could be retained for evidence purposes; First Amendment retaliation claim was properly dismissed as the officers had probable cause to arrest defendant; failure to train claims were properly dismissed.
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