Jared Clinton v. Ryan Garrett, No. 21-2763 (8th Cir. 2022)
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Plaintiff brought suit in state court against the officers for violation of his rights under the Fourth Amendment to the Federal Constitution and under Article I, Section 8 of the Iowa Constitution and for conspiracy to violate his federal and state constitutional rights. He also brought claims against the chief of police and the City of Des Moines for deliberate indifference under federal and state law. Defendants timely removed the suit to federal court. Plaintiff moved for summary judgment on all counts except for the number of damages; Defendants filed a cross-motion for summary judgment on the basis of federal qualified immunity and state immunity.
On appeal, Defendants argue that the district court erred in denying the individual officers qualified immunity on Plaintiff’s federal law claims, in denying the officers state immunity on his Iowa law claims, and in denying summary judgment to the City on his deliberate indifference claim.
The Eighth Circuit affirmed. The court reasoned that even combined with the fact that the stop occurred in an area known for criminal activity as well as a momentary display of nervousness on the part of a passenger, there is not enough here to justify the stop. The officers argue that there is no clearly established right to drive with a nervous passenger through a high-crime neighborhood with a temporary tag. These facts, in isolation, do not support a conclusion that Plaintiff’s vehicle was connected to unlawful activity in general, much less to the specific kind of unlawful activity for which the officers pulled him over.
Court Description: [Smith, Author, with Benton and Kelly, Circuit Judges] Civil case - Civil rights. Defendant police officers appeal the denial of their motion for summary judgment based on qualified immunity in this action alleging they violated plaintiff's Fourth Amendment rights and his rights under the Iowa constitution and by conspiring to violate his rights; the court does not have jurisdiction over the district court's denial of the defendants' motion for summary judgment on plaintiff's state law claims as the Iowa Supreme Court has not addressed the issue of whether an interlocutory appeal is available to review such a ruling; on the facts presented, defendants did not have a reasonable and articulable suspicion that plaintiff was violating the law by driving an unregistered vehicle or a vehicle with a falsified temporary tag; the right to be from from a stop under these circumstances was clearly established, and the district court did not err in denying the motion for summary judgment based on qualified immunity.
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