Irvin v. Richardson, No. 19-2364 (8th Cir. 2021)
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Plaintiffs Irvin and Bates filed 42 U.S.C. 1983 actions against police officers, the police chief, and the city, alleging violations of their Fourth Amendment rights and claims under Iowa law when Officers Richardson and Jupin stopped Irvin and Bates while responding to a 911 call.
The Eighth Circuit consolidated the appeals and affirmed the district court's grant of summary judgment dismissing Irvin's claims, as well as Bates's parallel state and federal claims. However, the court reversed the district court's grant of summary judgment dismissing Bates's federal and state law claims of false arrest after the initial encounter. The court concluded that the district court did not err by concluding that Officer Richardson had reasonable suspicion to stop and detain Irvin and Bates to determine whether they were involved in an unlawful firearm display during a public disturbance minutes earlier at a location they were walking away from. Because the officers had, at a minimum, arguable reasonable suspicion, they are entitled to qualified immunity on the investigative stop claims. The court affirmed the district court's grant of qualified immunity dismissing the Fourth Amendment claims where, under the circumstances, the force used by the officers did not turn the lawful Terry stop into an arrest. The court's conclusion that plaintiffs were not arrested defeats the false arrest claims.
However, the court concluded that under Iowa law the district court erred in granting defendants summary judgment on Bates's claim regarding his subsequent arrest for interference with official acts. Likewise, summary judgment was not appropriate as to Bates's section 1983 false arrest claim where the relevant facts are too confused and contested to conclude, as a matter of law, that Officer Richardson is entitled to qualified immunity. Finally, the court declined to resolve these Monell issues as a matter of law on this summary judgment record and therefore included these issues in reversing the grant of summary judgment dismissing Bates's separate false arrest claims.
Court Description: [Loken, Author, with Kelly and Erickson, Circuit Judges] Civil case - Civil rights. In an action against police officers and the City of Cedar Rapids arising out of an investigative stop of plaintiffs, the district court did not err in determining the officers had reasonable suspicion to stop and detain the men to determine whether they were involved in an earlier unlawful firearm display during a public disturbance at that location, and the officers were entitled to qualified immunity on the claim concerning the investigative stop; under the circumstances, the force used by the officers did not turn the lawful Terry stop into an arrest; the detention was no longer than necessary for the officers to pursue their investigation; the district court did not err in granting the officers qualified immunity dismissing the Fourth Amendment claims; the court's conclusion that plaintiffs were not arrested defeats their claims under Section 1983 and Iowa state law that they were falsely arrested without probable cause prior to the end of their Terry stop detention; however, under Iowa law the district court erred in granting defendants summary judgment on plaintiff Bates's claim concerning his subsequent arrest for interference with official acts; similarly, the court erred in granting defendants summary judgment on Bates's Section 1983 false arrest claim with respect to his post-Terry arrest; Bates's Monell claims are also remanded for further proceedings. Judge Kelly, concurring in part and dissenting in part.
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