Crysteal Davis v. Trevor Spear, No. 21-2419 (8th Cir. 2022)
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Defendants, Des Moines Police Department officers, lacking probable cause, took relatives of a stabbing victim to the station and held them for over three hours during which time the victim died. The district court denied qualified immunity, ruling for the family on their claims of illegal seizure and false arrest.
The Eighth Circuit affirmed the district court’s denial of qualified immunity. The court held both the duration and the nature of the seizure at issue exceeded the bounds of the Constitution.
The court reasoned that officers are entitled to qualified immunity unless (1) the evidence, viewed in the light most favorable to the plaintiffs, establishes a violation of a constitutional or statutory right, and (2) the right was clearly established at the time of the violation, such that a reasonable official would have known that his actions were unlawful. Here, the officers seized the family against their will and without probable cause. There was no “reasonable ground” for the officers’ action.
The court concluded that there was no minimally-intrusive Terry stop and the detention was the most intrusive means of questioning survivors after a violent crime. Further, officers of the Des Moines Police Department were on notice that they could not detain someone for questioning against their will, even in a homicide investigation, absent probable cause. The same evidence establishes the officers’ violation of sec. 1983 and the Fourth Amendment establishes a violation of the Iowa Constitution.
Court Description: [Benton, Author, with Shepherd and Stras, Circuit Judges] Civil case - Civil rights. In the aftermath of a stabbing where police were able to arrest the person responsible, they took three of the victim's family members to the police station for questioning and refused to allow them to go to the hospital where the victim was dying; plaintiffs brought this action for unreasonable seizure and false arrest. Held: the district court properly denied the defendants' motion for summary judgment based on qualified immunity; the seizures were unsupported by probable cause and were not reasonable; the constitutional right to be free from seizure absent probable cause was clearly established, including in cases involving this police department; defendants were not entitled to "all-due-care immunity" under Iowa law on the state law claims; the district court order granting plaintiffs partial summary judgment on their common-law false arrest or false imprisonment claim is affirmed, as that claim is necessarily decided by the resolution of the qualified immunity claim. Judge Stras, concurring.
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