Jorge Sanguinetti v. Collier County, Kevin Rambosk, Adam Dillman, John Scaduto, David Drucks, Michael Puka, and David Crisp, Jr.

Summary

The United States District Court for the Middle District of Florida grants defendants’ motions for summary judgment in Jorge Sanguinetti’s civil-rights action arising from his arrest and use of force by Collier County Sheriff’s Office deputies. The court concludes, among other things, that the plaintiff failed to establish municipal liability under 42 U.S.C. § 1983 and that probable cause defeated several false-arrest, false-imprisonment, and malicious-prosecution claims. The excerpt also addresses the handling of video evidence and the plaintiff’s improperly filed notice of clarification.

Holdings

1. Claims against Collier County and the sheriff in his official capacity failed because Sanguinetti did not establish a constitutional violation, a deliberately indifferent policy or custom, or a causal connection between a policy or custom and the alleged injury. A single incident is insufficient to establish the longstanding and widespread practice ordinarily required for municipal liability.
2. Probable cause defeated Sanguinetti's state and federal false-arrest and false-imprisonment claims and his state and federal malicious-prosecution claims. Deputy Scaduto had probable cause to arrest Sanguinetti for trespass because lounge employees requested assistance in removing him and Scaduto ordered him to leave, yet he remained.
3. The deputies were entitled to qualified immunity on the § 1983 excessive-force claim, and the related Florida battery claim failed. The force used to remove, subdue, and handcuff Sanguinetti was reasonable under the circumstances, and Sanguinetti did not show a clearly established right prohibiting the officers' conduct.
4. The deputies were entitled to qualified immunity on Sanguinetti's failure-to-intervene claim because there was probable cause for the arrest and no excessive force.
5. Sanguinetti's equal-protection claim under §§ 1981 and 1983 failed because he did not allege or present evidence that defendants intentionally discriminated against him on the basis of race.
6. The Florida negligent-supervision and negligent-training claims failed because Sanguinetti did not establish an underlying tortious act outside the scope of employment. In addition, governmental immunity barred the negligent-training claim because decisions concerning police training are discretionary governmental functions.

Questions Presented

1. Whether summary judgment was proper on Sanguinetti's § 1983 claims against Collier County and the sheriff in his official capacity for failure to establish a policy or custom causing a constitutional violation.
2. Whether probable cause defeated Sanguinetti's state and federal false-arrest, false-imprisonment, and malicious-prosecution claims.
3. Whether the deputies were entitled to qualified immunity on the Florida battery and § 1983 excessive-force claims.
4. Whether the deputies were entitled to qualified immunity on the § 1983 failure-to-intervene claim.
5. Whether Sanguinetti established intentional race discrimination under 42 U.S.C. § 1981.
6. Whether Sanguinetti's Florida negligent-supervision and negligent-training claims failed for lack of an underlying tort and, as to training, sovereign immunity.

Disposition

other