Michael Klein v. Warren Steinkamp, No. 21-3039 (8th Cir. 2022)
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Plaintiff sued, now retired, police officer, after an encounter that led to Klein’s arrest and a truncated prosecution. The district court granted Defendant’s motion for summary judgment, and Plaintiff appealed the dismissal of his claims alleging unlawful seizure, false arrest, and malicious prosecution.
The Eighth Circuit affirmed, concluding that the seizure and arrest claims were untimely and that the malicious prosecution claim fails on the merits. The court explained that Plaintiff’s false arrest claim accrued when he was bound over for trial on June 20, 2017, and his unlawful seizure claim accrued at the time of the seizure, on June 19, 2017. The action filed on November 6, 2019, was therefore untimely as to these claims as well. The district court properly granted Defendant’s motion for summary judgment on Plaintiff’s claims alleging false arrest and unlawful seizure under both federal law and Iowa law.
Moreover, the court concluded that Defendant had probable cause to arrest Plaintiff or possession with intent to deliver more than five grams of methamphetamine, and failure to possess a tax stamp for seven grams of methamphetamine. Plaintiff argues that Defendant lacked probable cause because his search for the evidence violated the Fourth Amendment and the Iowa Constitution. The existence of probable cause in a civil action, however, is measured based on all evidence known to the arresting officer, whether or not it would have been admissible at trial.
Court Description: [Colloton, Author, with Wollman and Shepherd, Circuit Judges] Civil case - Civil rights. The district court properly dismissed plaintiff's state law claims for false arrest and unlawful seizure as barred by the relevant Iowa two-year statute of limitations; alternatively, the claims were also barred by the two-year limitations period in Section 1983; plaintiff's malicious prosecution claim was properly dismissed as without merit as there was probable cause for his arrest for possession of methamphetamine and failure to have a tax stamp
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