Just v. Kuykendall, No. 20-1049 (8th Cir. 2021)
Annotate this Case
Plaintiff filed suit against Officers Kuykendall and Henry, arguing that they violated his Fourth and First Amendment rights. After the district court denied defendants' motion for summary judgment on the basis of qualified immunity, they filed this interlocutory appeal.
Concluding that it has jurisdiction under the collateral order doctrine, the Eighth Circuit reversed the district court's denial of defendants' motion for summary judgment. The court concluded that John Doe's and the third party's reports were sufficient to have provided probable cause to arrest plaintiff for assault in the fourth degree under Missouri law. In this case, the facts that plaintiff directs the court to do not diminish the officers' probable cause to believe, at the time of plaintiff's arrest, that he had committed a crime. Furthermore, the fact that no formal charges were initiated against plaintiff does not retroactively diminish the reasonableness of the officers' belief. Even if the officers were mistaken that probable cause existed, that mistake was "objectively reasonable" and arguable probable cause exists, entitling them to qualified immunity. Finally, the officers were also entitled to qualified immunity on plaintiff's First Amendment retaliation claim.
Court Description: [Shepherd, Author, with Gruender and Benton, Circuit Judges] Civil case - Civil rights. The district court erred in denying the defendant police officers' motion for summary judgment based on qualified immunity on plaintiff's Fourth Amendment claims as the reports the officers had received provided probable cause to arrest plaintiff for assault in the fourth degree under Missouri law; even if the officers were mistaken that probable cause existed, that mistake was objectively reasonable, and arguable probable cause existed, entitling the officers to qualified immunity; with respect to plaintiff's First Amendment claim based on retaliatory arrest, the officers were also entitled to qualified immunity on this claim based on the existence of probable cause to arrest plaintiff.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.