Allen v. Monico, No. 21-1428 (8th Cir. 2022)
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After a jury found plaintiff not guilty of a drug trafficking offense, he filed a civil rights action against two police officers alleging they conspired to include false statements in an affidavit of probable cause executed shortly after his arrest.
The Eighth Circuit affirmed the district court's grant of the motion to dismiss based on qualified immunity where the affidavit provided arguable probable cause for plaintiff's arrest even without the allegedly false statements at issue. The court concluded that the uncontested portions of the affidavit show officers knew at the time that plaintiff repeatedly had been with the targets of their investigation close in time to cocaine sales. Viewed in totality through the lens of common sense, the court stated that the affidavit with the alleged falsehoods removed still supports probable cause. The court affirmed the dismissal of all plaintiff's claims as they are derivative of the probable cause argument.
Court Description: [Kelly, Author, with Benton and Erickson, Circuit Judges] Civil Case ? Civil Rights. After his acquittal, Allen brought civil rights action against two police officers, alleging they conspired to provide false statements in an affidavit of probable cause executed after his arrest, resulting in his unreasonable arrest, false imprisonment, and malicious prosecution. The district court?s grant of qualified immunity to the officers is affirmed, as the affidavit provided arguable probable cause for his arrest even without the allegedly false statements. Reviewing the uncontested portions of the affidavit, and viewed in totality with the relevant circumstances, the affidavit with the alleged falsehoods removed still supports probable cause and thus the district court did not err in concluding the officers were entitled to qualified immunity.
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