Picatti v. MinerAnnotate this Case
This appeal arose from the district court’s decision to bar Steven Picatti’s 42 U.S.C.
section 1983 claims against two deputies on the basis of collateral estoppel. In July 2014, Picatti struggled to drive home because road access was blocked for the Eagle Fun Days parade. After circumventing some orange barricades, Picatti drove toward two uniformed deputies who were on foot patrol by a crosswalk, which was marked with a large sign reading: “road closed to thru traffic.” The factual background from that point was heavily disputed. Picatti alleged Deputy Miner hit the hood of his car, then pulled Picatti out of his truck to tase and arrest him. The deputies contended Picatti “bumped” Deputy Miner with his truck and then resisted arrest, forcing them to tase him into submission. Picatti was ultimately arrested on two charges: resisting and obstructing officers and aggravated battery on law enforcement. At the end of his preliminary hearing, Picatti was bound over. Prior to trial, Picatti accepted a plea agreement in which he pleaded guilty to disturbing the peace for “failing to obey a traffic sign and driving into a restricted pedestrian area.” The court entered a judgment of conviction, which was not appealed, overturned, or expunged. Two years later, Picatti brought a 42 U.S.C. section 1983 suit against his arresting deputies, claiming deprivations of his protected rights to be free from (1) unreasonable seizure, (2) excessive force, and (3) felony arrest without probable cause. The district court granted summary judgment to the defending deputies holding that collateral estoppel barred Picatti from relitigating probable cause once it was determined at the preliminary hearing. Picatti timely appealed. The Idaho Supreme Court affirmed the order granting summary judgment to the deputies as to Picatti’s claims of false arrest and unreasonable seizure; however, the Court vacated the summary judgment as to Picatti’s excessive force claim. The district court correctly applied the doctrine of collateral estoppel to Picatti’s claims of false arrest and unreasonable seizure, but not as to excessive force. In addition, the Court could not find as a matter of law that the deputies were entitled to qualified immunity on Picatti’s excessive force claim when there was a genuine issue of material fact.