Summary
The Supreme Court of Alabama considered whether the City of Birmingham was liable under 42 U.S.C. § 1983 for the warrantless arrest of Eric L. Major for third-degree domestic violence. The court held that undisputed facts established probable cause for the arrest, meaning Major failed to demonstrate a constitutional injury. The court reversed the trial court's judgment based on the jury verdict and rendered judgment in favor of the City.
Topics
Practice areas
Questions Presented
- Whether the undisputed facts known to Officer Anger established probable cause to arrest Major for third-degree domestic violence.
- Whether Major established a constitutional injury sufficient to support his 42 U.S.C. § 1983 claim against the City.
- Whether the City was entitled to judgment as a matter of law after the jury returned a verdict for Major.
Holdings
- The undisputed facts known to Officer Anger provided probable cause, as a matter of law, to arrest Major for third-degree domestic violence.
- Major failed to establish a constitutional injury because his arrest was supported by probable cause.
- The City was entitled to judgment as a matter of law, and the trial court's judgment for Major was reversed and judgment was rendered for the City.
Key quotations
“In order to hold a governmental entity liable for an injury inflicted by an employee or agent of the entity, an individual must demonstrate that he or she suffered "a constitutional injury at the hands of the individual [governmental employee or agent.]"” (477)
“Therefore, as a matter of law, the undisputed facts provided Officer Anger with probable cause to arrest Major for committing the offense of third-degree domestic violence.” (478)
“Because the undisputed facts were sufficient to give Officer Anger probable cause to arrest Major for third-degree domestic violence against Joseph, we conclude that Major has not demonstrated that he suffered a constitutional injury to sustain his § 1983 claim.” (480)
Factual background
Officer Anger arrested Major after Joseph reported that Major had assaulted and attempted to rape her. The officers observed swelling and discoloration on Joseph's face, marks on her neck and wrists, disheveled clothing, and dark red stains on Joseph's clothing and in Major's car. Major and Joseph both acknowledged that they had previously been engaged, and both gave accounts indicating that an altercation had occurred.
Procedural history
Major was arrested and charged with assault and later third-degree domestic violence after a police investigation of an altercation with a former fiancée. He was initially convicted in Birmingham municipal court but was acquitted on appeal in Jefferson Circuit Court. Major then sued the City, Officer Anger, and Joseph on multiple theories, including a § 1983 Fourth Amendment claim. The circuit court submitted the § 1983 claim against the City to the jury, which awarded Major $500,000; the City's postjudgment motion was denied by operation of law, leading to this appeal.