Summary
The United States Court of Appeals for the Fourth Circuit affirmed dismissal of L.M.'s 42 U.S.C. § 1983 malicious prosecution claims against Detective Jonathan Graham. The court held that the complaint did not plausibly allege that L.M.'s juvenile detention was unsupported by probable cause, because the investigation included eyewitness accounts and other corroborating information. The court also held that L.M. failed to adequately allege that Graham caused the seizure, given the independent probable-cause determination by the juvenile intake officer.
Court
United States Court of Appeals for the Fourth Circuit
Jurisdiction
United States Court of Appeals for the Fourth Circuit
Decision date
February 27, 2026
Docket number
25-1213
Disposition
affirmed
Questions Presented
- Whether L.M. plausibly alleged that his seizure pursuant to the juvenile petition was unsupported by probable cause because Graham omitted allegedly exculpatory information.
- Whether L.M. plausibly alleged that Graham caused his seizure when a Juvenile Intake Officer made the probable-cause determination.
- Whether the district court properly dismissed the § 1983 and Virginia-law malicious-prosecution claims under Rule 12(b)(6).
Holdings
- The complaint did not plausibly allege that L.M.'s seizure lacked probable cause. Considering the totality of the circumstances, the witness identifications and supporting information established a fair probability that L.M. was one of the perpetrators, and the alleged omissions were not material enough to negate probable cause.
- The complaint did not plausibly allege that Graham caused L.M.'s seizure. Although an independent probable-cause decision by a Juvenile Intake Officer does not automatically break the causal chain, L.M. alleged no facts showing that Graham withheld material information from or unduly influenced the Juvenile Intake Officer.
- The district court properly dismissed L.M.'s federal and state malicious-prosecution claims against Graham for failure to state a claim.
Court Document
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