Corey R. Kendig v. Nicholas Stolar

Summary

The United States Court of Appeals for the Third Circuit affirmed summary judgment in favor of Pennsylvania State Trooper Nicholas Stolar in Corey Kendig’s 42 U.S.C. § 1983 action alleging false arrest, false imprisonment, and malicious prosecution. The court held that known facts conclusively supporting self-defense can be relevant exculpatory information that should be included in a probable-cause affidavit, but qualified immunity applied because the duty was not clearly established when Stolar acted.

Holdings

1. An affirmative defense is relevant to a probable-cause determination when a reasonable police officer would conclusively know that the defense either negates the charged offense's requisite mental state or excuses the conduct. For the offenses charged here, known facts establishing self-defense were exculpatory and relevant to the magistrate's probable-cause determination.
2. An officer is not required to evaluate the merits of every potential affirmative defense, investigate facts that might establish a defense, or resolve conflicting evidence. But when the officer gathers information bearing on self-defense and conclusively knows that the defense negates the charged offense's mens rea or excuses the conduct, the officer must provide those facts to the magistrate.
3. The omission of known facts establishing Kendig's self-defense implicated his Fourth Amendment right to be free from charges and arrests without probable cause.
4. Stolar was entitled to qualified immunity because, at the time of his conduct, it was not clearly established in the Third Circuit that omitting facts supporting an affirmative defense from a probable-cause affidavit violated the Fourth Amendment.

Questions Presented

1. Whether known facts supporting Kendig's self-defense claim were relevant and required to be included in the affidavit of probable cause for the charged offenses.
2. Whether omitting known facts supporting self-defense violated Kendig's Fourth Amendment right to be free from arrest, detention, and prosecution without probable cause.
3. Whether that Fourth Amendment right was clearly established when Stolar prepared the affidavit, defeating qualified immunity.
4. Whether the District Court properly granted summary judgment to Stolar.

Disposition

affirmed