Michael Moore v. Kenneth Finley, et al.

Summary

The United States District Court for the Northern District of Alabama addresses multiple motions in Michael Moore’s civil rights action arising from his arrest during a domestic-dispute response. The court grants in part and denies in part the deputy defendants’ motion for summary judgment and grants the motions for judgment on the pleadings filed by the sheriff and district attorney. The opinion principally analyzes Fourth Amendment claims concerning warrantless entry into a fenced residential area, false arrest, malicious prosecution, false imprisonment, and public-records requests.

Holdings

1. Deputies Finley and Moise violated Moore's Fourth Amendment right by entering his fenced yard without consent, a warrant, or exigent circumstances. The right was clearly established, so qualified immunity did not shield the deputies. Moore was entitled to summary judgment on liability for Count One, while the deputies were not entitled to summary judgment.
2. The deputies were entitled to qualified immunity and summary judgment on Moore's false-arrest claims because the facts known to them supplied at least arguable probable cause to arrest Moore for domestic violence in the third degree.
3. Deputy Moise was entitled to summary judgment on Moore's malicious-prosecution claims because Moore failed to create a genuine dispute that Moise intentionally or recklessly omitted material information from the criminal complaint or that the legal process was constitutionally infirm.
4. Deputy Finley was entitled to summary judgment on Moore's false-imprisonment claim because the arrest was supported by probable cause and the record did not show continued detention after it became known that Moore was entitled to release.
5. Sheriff Pettway and District Attorney Carr were entitled to judgment on the pleadings on Moore's Alabama Open Records Act claims because the court would not create a monetary remedy absent legislative authorization, Moore lacked standing to seek damages for a wholly past violation, and any request for injunctive relief was moot after the requested information was provided.
6. The court denied as moot the motions to compel and to deem documents genuine, denied the motions for sanctions and to strike expert designations and summary-judgment briefing, and denied leave to serve subpoenas that would circumvent the ordinary discovery rules.

Questions Presented

1. Whether Deputies Finley and Moise violated the Fourth Amendment by entering the fenced curtilage of Moore's home without a warrant, consent, probable cause, and exigent circumstances, and whether qualified immunity applied.
2. Whether Deputies Finley, Moise, and Garrett had arguable probable cause to arrest Moore for domestic violence, defeating his false-arrest claims.
3. Whether Moore established a Fourth Amendment malicious-prosecution claim based on alleged omissions or misstatements in the criminal complaint.
4. Whether Moore established a § 1983 false-imprisonment claim against Deputy Finley.
5. Whether the Alabama Open Records Act provides a monetary remedy for the alleged failure to disclose the deputies' names and whether Moore had standing to seek such relief.
6. Whether Moore's request for injunctive relief against Sheriff Pettway was moot after the requested names were provided.
7. Whether the discovery, sanctions, authentication, expert-designation, and subpoena motions should be granted.

Disposition

other