Cronin v. Peterson, No. 19-1054 (8th Cir. 2020)
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Plaintiff, a police officer, filed suit under 42 U.S.C. 1983 based on the police department's investigation of him after it received allegations that plaintiff had purchased illegal steroids and interfered with a department investigation. In this case, defendant's home, police locker, police cruiser, and wife's vehicle were searched. Furthermore, his blood and urine were taken and analyzed.
The Eighth Circuit affirmed the district court's dismissal of plaintiff's claim that Sergeant Koepke had unlawfully detained plaintiff in violation of his Fourth Amendment rights where, taken together, the facts do not establish that Koepke lacked sufficient reasonable and articulable suspicion that plaintiff might be involved in criminal activity. Therefore, Koepke was entitled to qualified immunity. The court affirmed the district court's grant of summary judgment on plaintiff's Fourth Amendment claims that Koepke had unlawfully arrested plaintiff where Koepke was entitled to qualified immunity because the length of plaintiff's detention was not unreasonable under the circumstances. The court also affirmed summary judgment based on qualified immunity for Captain Peterson and Legal Advisor Peters and concluded that any omitted material facts from their warrant application was immaterial. Finally, the court affirmed summary judgment based on qualified immunity to Sergeant Reynolds where Reynold's search of plaintiff's wife's vehicle, which was not the vehicle identified in the search warrant, was authorized under the automobile exception to the warrant requirement.
Court Description: [Wollman, Author, with Kelly and Stras, Circuit Judges] Civil case - Civil rights. In action alleging police officer had unlawfully detained plaintiff, that a police captain and a legal advisor had omitted material facts from a warrant application and that another officer had searched plaintiff's wife's car without a warrant, all in violation of plaintiff's civil rights, the district court granted the defendants summary judgment. Held: the facts, as alleged in plaintiff's complaint did not establish that defendant police sergeant Kopeke lacked sufficient reasonable and articulable suspicion that plaintiff might be involved in criminal activity, and plaintiff's initial detention was not unconstitutional and Koepke was entitled to qualified immunity; the length of plaintiff's detention was not unreasonable under the circumstances and Koepke was entitled to qualified immunity on plaintiff's claim that the length of the detention turned into an unconstitutional de facto arrest; the inclusion of facts plaintiff claims were improperly omitted from the warrant applications would not have negated the existence of probable cause for the issuance of the search warrants; subsequent warrant and warrant extension affidavits established probable cause to search defendant's phone for incriminating texts and voice mails, and the material plaintiff asserts was improperly omitted would not have negated the existence of probable cause; search of plaintiff's wife's car, which had been omitted from the warrant application, was authorized under the automobile exception to the warrant requirement, and the officer who conducted the search was entitled to qualified immunity on plaintiff's unlawful warrant-execution claim.
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