Summary
This Memorandum Opinion and Order addresses a defendant's motion for summary judgment in a civil rights action arising from a property dispute and subsequent arrest for trespassing. The court analyzes claims of false arrest, malicious prosecution, conspiracy, and racial discrimination under 42 U.S.C. §§ 1983, 1985, and 1982. Applying the qualified immunity standard, the court finds that the law enforcement officers had arguable probable cause or lacked personal involvement, and concludes that the plaintiff failed to present sufficient evidence to support his conspiracy and racial discrimination claims. Accordingly, the court grants summary judgment in favor of the county and individual defendants.
Topics
Practice areas
Questions Presented
- Whether the county deputies are entitled to qualified immunity on false arrest/imprisonment claims.
- Whether the county deputies are entitled to qualified immunity on malicious prosecution claims.
- Whether the county defendants are entitled to qualified immunity on conspiracy claims under 42 U.S.C. §§1983 and 1985.
- Whether the county defendants are entitled to qualified immunity on racial discrimination claims under 42 U.S.C. §1982.
- Whether Sevier County can be held liable in its official capacity.
- Whether Sheriff Gentry can be held liable in his individual capacity as a supervisor.
Holdings
- Defendants are entitled to qualified immunity and summary judgment on all false arrest/imprisonment claims.
- Defendants are entitled to qualified immunity and summary judgment on all malicious prosecution claims.
- Defendants are entitled to qualified immunity on the conspiracy claim.
- Defendants are entitled to qualified immunity on the racial discrimination claim.
- Sevier County is entitled to summary judgment; no municipal policy or custom causing a constitutional violation was shown.
- Sheriff Gentry is entitled to qualified immunity on the supervisor liability claim.
Key quotations
“The standard for summary judgment is well established. When a party moves for summary judgment, “[t]he court shall grant summary judgment if the movant shows that there is no genuine dispute as to any material fact, and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a);” (at 248)
Factual background
The dispute arose over ownership of 80, 3, and 55 acres of land in Sevier County, Arkansas. Plaintiff entered the disputed area, was arrested for trespass after a warrant was issued based on information from the Pickett Defendants and county deputies, and subsequently sued county officials and the Pickett Defendants alleging constitutional violations.
Procedural history
Plaintiff filed a complaint on March 1, 2023 alleging false arrest, malicious prosecution, conspiracy, racial discrimination, county liability and supervisor liability claims under 42 U.S.C. §§1982, 1983, 1985. Defendants filed a motion for summary judgment, which the court considered and granted.