42 USC § 1983; Qualified immunity & summary disposition standards; False arrest; Malicious prosecution; Monell v Department of Soc Servs claim

Applying the “ordinary” standards for summary judgment to the two-step qualified immunity analysis, the court affirmed summary judgment for defendant-Deffendoll on plaintiff-Alford’s false-arrest and malicious-prosecution claims, holding that Deffendoll had probable cause to both arrest and charge him. Officers Deffendoll and defendant-Smith stopped Alford’s vehicle, resulting in three state drug charges. He was jailed and his parole revoked before the charges were dismissed. Alford sued the officers and defendant-county under § 1983, asserting claims for false arrest and malicious prosecution against the officers and a Monell claim against the county. The district court granted all defendants summary judgment. On appeal, the court explained that “the Supreme Court has instructed that ordinary summary-judgment standards apply at both steps” of the qualified immunity inquiry. As to the false arrest claim, the court held that Deffendoll had “probable cause to arrest Alford for simple possession of heroin” under Tennessee law. While Alford claimed, among other things, that the drugs belonged to his passenger, the drugs and drug paraphernalia were found in the vehicle’s cab. “A reasonable officer could have concluded that” he and his passenger jointly possessed the items. The claim against Smith failed “because, as the district court found, Alford did not adequately demonstrate that Smith was an arresting officer.” Next, although the district court erred by applying an incorrect analysis for determining probable cause in the context of a malicious prosecution claim, the court agreed that Deffendoll was entitled to qualified immunity on this claim because he had probable cause to charge Alford under Tennessee law. It also held that Alford’s Monell claim failed where there was no constitutional violation.