Deandre D. Currington v. Dustin R. Folk

Summary

The United States District Court for the Middle District of Alabama granted Defendant Dustin Folk’s motion for summary judgment in Deandre D. Currington’s claims arising from his arrest and subsequent warrants. The court held that probable cause supported the warrantless arrest and that Currington failed to show that Folk intentionally or recklessly included materially false information in the probable cause affidavit. The court concluded that qualified immunity applied, dismissed the action with prejudice, and denied as moot the requested injunctive relief.

Holdings

1. Officer Folk had probable cause to arrest Currington for resisting arrest, regardless of the other offenses Folk may have believed had occurred. Under the any-crime rule, that probable cause defeats the false-arrest claim.
2. Currington failed to show that Officer Folk intentionally or recklessly made material misstatements or omissions necessary to support the arrest warrants. The affidavit established arguable probable cause for stalking and violating a protection order even after considering Currington's alleged inaccuracies.
3. Officer Folk was entitled to qualified immunity because he acted within the scope of his discretionary law-enforcement authority and Currington failed to establish a constitutional violation.

Questions Presented

1. Whether Officer Folk had probable cause, or at least arguable probable cause, to arrest Currington without a warrant for resisting arrest, defeating Currington's Fourth Amendment false-arrest claim.
2. Whether the warrant-based detention supported a Fourth Amendment malicious-prosecution claim because Officer Folk allegedly included intentional or reckless material misstatements or omissions in the probable-cause affidavit.
3. Whether Officer Folk was entitled to qualified immunity on Currington's false-arrest and malicious-prosecution claims.

Disposition

dismissed