Dennis Ryno v. City of Waynesville, No. 22-1046 (8th Cir. 2023)
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Appellant brought a variety of state and federal claims against the City of Waynesville (the City), the Waynesville Police Department (WPD), WPD Chief, WPD Officers, and Pulaski County Prosecutor (collectively, Appellees). The district court dismissed most of Appellant’s claims pursuant to Federal Rule of Civil Procedure 12(b)(6), and later granted the Appellees’ motion for summary judgment on Appellant’s remaining claims. Appellant appealed the grant of summary judgment. Appellant conceded that his unreasonable seizure and conspiracy-to-cause-false-arrest claims do not involve the officer. Additionally, Appellant clarified that his appeal of the unreasonable search claim is limited to “the district court’s determination about the computer and home searches.”
The Eighth Circuit affirmed. The court held that, at minimum, it was objectively reasonable for the police Chief and Officer to believe that Appellant had committed or was committing a violation of Mo. Rev. Stat. Section 455.085.2, Mo. Rev. Stat. Section 565.090.1 or Mo. Rev. Stat. Section 565.225.2-3. Accordingly, arguable probable cause exists, meaning that it was not clearly established that arresting Appellant on these facts would violate his right to be free from unlawful seizure. Thus, the court affirmed the district court’s grant of summary judgment on Appellant’s unreasonable-seizure claim because Appellees are entitled to qualified immunity.
Further, the court concluded that reasonable suspicion supported the search of Appellant’s house. Moreover, because there is only one minor inaccuracy in the otherwise thorough search warrant affidavit for Appellant’s computer, and the issuing judge found that there was enough evidence to support a finding of probable cause, that judgment is entitled to deference on appeal.
Court Description: [Shepherd, Author, with Colloton and Grasz, Circuit Judges] Civil case - Civil rights. At the time the defendant officer arrested plaintiff, a reasonable officer would have believed plaintiff had committed or was committing the offenses of violating an order of protection, stalking or harassment; as a result, plaintiff's arrest was not a Fourth Amendment violation, and the officers were entitled to qualified immunity; even if the officers did not have probable cause to arrest plaintiff, his right to be free from unreasonable seizure was not clearly established under these facts; with respect to plaintiff's claim for conspiracy to cause false arrest or unreasonable seizure, defendant was, at the time of the incident, subject to a probation condition requiring him to submit to searches of his person and residence; under these circumstances, the Fourth Amendment requires no more than a reasonable suspicion to conduct a search of the plaintiff's house, even without a warrant, and the officers had a reasonable suspicion; the court assumes, without deciding, that the reasonable suspicion standard also applied to a search of the plaintiff's computer; the officers were entitled to qualified immunity on plaintiff's unreasonable search claim.
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