Baldridge v. Cordes, 350 Ark. 114

Summary

The Supreme Court of Arkansas affirmed summary judgment for an Arkansas State Trooper in a civil-rights action arising from Jeffrey Baldridge’s arrest for driving while intoxicated and related offenses while riding a horse near a highway. The court held that the trooper was entitled to qualified immunity because her observations provided an objectively reasonable basis for probable cause to arrest Baldridge for public intoxication, even though the motor-vehicle charges were legally improper. A dissent argued that charging motor-vehicle offenses based on horseback riding was not objectively reasonable.

Holdings

1. The circuit court properly granted summary judgment because Cordes was entitled to qualified immunity from Baldridge's federal and state civil-rights claims.
2. Cordes's arrest was protected by qualified immunity because, even if the stated motor-vehicle charges were incorrect, the circumstances provided probable cause to arrest Baldridge for public intoxication, a closely related offense.
3. Cordes did not lose qualified immunity merely because she lacked authority to amend the DWI charge after the arrest.

Questions Presented

1. Whether the circuit court properly granted summary judgment on the ground that Trooper Cordes was entitled to qualified immunity.
2. Whether Cordes had an objectively reasonable basis, or arguable probable cause, to arrest Baldridge when he was riding a horse near a highway after an accident.
3. Whether Cordes's inability under Arkansas law to amend the DWI charge eliminated her qualified immunity.

Disposition

affirmed