Scott v. Sinagra

Citations: 167 F. Supp. 2d 509; 2001 U.S. Dist. LEXIS 11955; 2001 WL 1173236Docket: 1:00-cv-00276

Court: District Court, N.D. New York; August 16, 2001; Federal District Court

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Charles Scott filed a lawsuit against multiple defendants, including police officers and municipal entities, alleging violations of his constitutional rights stemming from a traffic stop on May 24, 1997. Scott claims violations of the Fourth and Fourteenth Amendments, 42 U.S.C. § 1983, New York State Constitution Article 1, § 12, and common law negligence. The defendants, including officers Robert J. Keller and John O. Sheeley, sought summary judgment to dismiss the claims, which Scott opposed.

On the day of the incident, Keller and Sheeley were at the New York State Thruway Kingston exit plaza when they received a report about Scott's vehicle, which allegedly had a cracked windshield and lacked a license plate. Keller stopped Scott's vehicle, and Sheeley approached the passenger side, where Scott was seated. Sheeley claimed to smell marijuana and noticed Scott's nervous demeanor and a bulge in his pocket, prompting him to ask Scott to exit the vehicle. Upon Scott's exit, Sheeley reportedly saw a bag of marijuana on the passenger side floor.

Scott contested the officers' observations, denying the presence of marijuana, his nervousness, and the bulge in his pocket, asserting he complied with the officer's request. A struggle ensued after Scott resisted a pat down and fled, leading to injuries for the officers but none for Scott. George Carlson, another officer with a K-9 unit, later intervened and claimed to have seen Scott choking Sheeley. Carlson used a metal lead to push Scott away, allegedly causing a superficial cut to Scott's head. Scott denied choking Sheeley and asserted he was struck by a flashlight during the altercation.

Following the incident, Scott was arrested and charged with two counts of assault, resisting arrest, and possession of marijuana. Officer Joseph Sinagra prepared the felony accusatory statement after Scott was handcuffed.

Marijuana observed by Sheeley in the passenger side of a vehicle was not recovered, nor was there an explanation for a bulge in Scott's pocket. The vehicle's driver was not charged, and a preliminary hearing on May 27, 1997, took place in the Town of Ulster Court where both Keller and Sheeley testified. Scott, represented by counsel, did not cross-examine witnesses or testify, though he denied the allegations against him. The Town Court found probable cause for his arrest, but the Grand Jury did not indict him, resulting in the dismissal of all charges.

Regarding summary judgment standards, a party may obtain summary judgment if the record shows no genuine issue of material fact and entitlement to judgment as a matter of law, as stated in Fed. R. Civ. P. 56(c). The court assesses whether a reasonable jury could find for the nonmoving party, considering the evidence in a light favorable to that party. However, mere speculation or unsubstantiated claims are insufficient for the nonmoving party.

Defendant Joseph A. Sinagra, who arrived after Scott was detained, was justified in writing reports based on information from other officers. The plaintiff's argument that Sinagra knew the information was inadequate to charge him lacks merit, as he was not involved in alleged unlawful force and relied appropriately on provided information.

On municipal liability under 42 U.S.C. § 1983, a municipality is accountable for constitutional torts caused by employees acting under official policy, but not for individual wrongful acts under respondeat superior. Liability may arise from failure to adequately train police officers if it reflects deliberate indifference to individuals' rights.

Training for police officers must be deemed "obvious" and necessary to prevent violations of constitutional rights. The plaintiff failed to provide evidence showing that the city or town had policies encouraging the alleged officer misconduct, or that there was a lack of training or supervision contributing to the incident. The absence of evidence indicating that training needs were "obvious" or that the failure to train constituted "deliberate indifference" undermines the plaintiff's § 1983 claim. The plaintiff's assertion that municipal defendants are liable for inadequate training in probable cause lacks factual support, and thus all claims against the municipalities should be dismissed.

Regarding the false arrest claim, the standard for probable cause aligns with New York State common law. An officer is justified in making an arrest if they have sufficient facts to warrant a prudent belief that an offense has been committed. While the Town of Ulster Court's preliminary hearing did not establish full adjudication on probable cause, its finding serves as some evidence supporting the defendants' argument. However, conflicting accounts of the incident indicate that material facts are disputed, necessitating a trial to resolve the issue of probable cause.

On the claim of excessive or unreasonable force, not every action by police constitutes a rights violation; rather, the force used must be "objectively reasonable." The standard for evaluating such claims relies on the context of the situation, as established in precedents.

Reasonableness in evaluating police conduct must be assessed from the viewpoint of a reasonable officer at the time of the incident, not with hindsight. Malice or intent is not necessary to establish excessive force, which becomes irrelevant if an arrest is deemed unlawful; in such cases, any force used is also unlawful. The court notes that if a jury finds the arrest unlawful, the force used is automatically excessive, and there is sufficient factual dispute regarding the reasonableness of the force employed by officers Carlson, Keller, and Sheeley, which prevents summary judgment in their favor.

For the malicious prosecution claim, the plaintiff must demonstrate that the defendant initiated prosecution without probable cause, with malice, and that the prosecution ended favorably for the plaintiff. The first and fourth elements are satisfied, but the second element regarding probable cause remains disputed, and malice could be inferred from the force used. Thus, summary judgment for the officers on this claim is inappropriate.

Qualified immunity for officers hinges on whether it was reasonable for them to believe probable cause existed or if competent officers could disagree on this issue. Given the plaintiff's favorable facts, the officers are not entitled to qualified immunity as a matter of law, indicating that this matter should also be presented to a jury.

Regarding state law claims, only intentional acts by the officers are actionable, and a negligence claim is not viable, leading to its dismissal. Consequently, the court orders the dismissal of the complaint against certain defendants while denying motions to dismiss related to false arrest, excessive force, and malicious prosecution claims against other officers. Remaining causes of action are also dismissed, with state claims decided on the same grounds as federal claims.