Gabriel Jordan v. Laura Franklin, Magen Dodge, and Kayra Lopez

Summary

The United States District Court for the District of Colorado granted defendants’ motions for summary judgment on Gabriel Jordan’s 42 U.S.C. § 1983 malicious-prosecution claim. The court held that Kayra Lopez did not act under color of state law and that defendants Magen Dodge and Laura Franklin had, at minimum, arguable probable cause supporting qualified immunity. The court dismissed the remaining state-law claims without prejudice for lack of subject-matter jurisdiction, denied Jordan’s summary-judgment motion, and closed the case.

Holdings

1. Lopez did not act under color of state law merely by reporting her observations to authorities. Her report was not an exercise of authority vested in her as a public-safety cadet, and the undisputed evidence did not establish coercion, joint action, conspiracy, or state influence.
2. Dodge and Franklin were entitled to qualified immunity because, at a minimum, they had arguable probable cause, and Jordan failed to identify clearly established law showing that their conduct violated the Fourth Amendment.
3. The court declined to exercise supplemental jurisdiction over the remaining state-law claims and dismissed them without prejudice for lack of subject-matter jurisdiction.

Questions Presented

1. Whether Lopez acted under color of state law when she reported Jordan's alleged conduct to law-enforcement authorities, such that she could be liable under 42 U.S.C. § 1983.
2. Whether Dodge and Franklin were entitled to qualified immunity on Jordan's § 1983 malicious-prosecution claim because arguable probable cause existed.
3. Whether the court should exercise supplemental jurisdiction over the remaining state-law claims after disposing of the sole federal claim.
4. Whether the plaintiff's passing references to § 1983 in his summary-judgment motion constituted a procedurally proper request to amend the complaint.

Disposition

other