Christopher P. White v. Tyson Havens, et al.

Summary

The United States District Court for the Middle District of Pennsylvania partially adopted and partially rejected a magistrate judge’s report and recommendation concerning defendants’ motion for summary judgment. The court denied summary judgment on Christopher P. White’s § 1983 malicious-prosecution claim because disputed declarations created genuine issues of material fact regarding probable cause and malice, but granted summary judgment on the civil-conspiracy claim for lack of evidence of concerted action. The court also declined to apply qualified immunity at the summary-judgment stage because factual disputes remained.

Holdings

1. Summary judgment was inappropriate because the competing declarations created a genuine dispute of material fact as to whether Rachael had probable cause to initiate the criminal prosecution.
2. The motion for summary judgment was properly denied because, if a jury credited White's account, it could infer malice from the absence of probable cause and from alleged fabrication of testimony and a police report.
3. Defendants were entitled to summary judgment on the civil-conspiracy claim because White presented no evidence that the defendants agreed or acted in concert to maliciously prosecute him.
4. The court declined to apply qualified immunity at that time because disputed historical facts concerning whether Rachael fabricated evidence and prosecuted White without probable cause were material to the immunity analysis.

Questions Presented

1. Whether competing declarations concerning whether White possessed or sold controlled substances created a genuine dispute of material fact regarding probable cause for the criminal prosecution.
2. Whether the evidence permitted a jury to find malice for purposes of White's § 1983 malicious-prosecution claim.
3. Whether White presented evidence of agreement and concerted action sufficient to sustain his § 1983 civil-conspiracy claim.
4. Whether defendants were entitled to qualified immunity at summary judgment despite disputed historical facts concerning whether Rachael fabricated evidence and prosecuted White without probable cause.

Disposition

other