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Dominguez v. Figueroa Sancha
Citation: 373 F. Supp. 3d 333Docket: CIVIL NO. 12-1707 (PG)
Court: United States District Court; February 6, 2019; Federal District Court
Plaintiffs Danny Dominguez and Elionai Fernandez have sued Defendants Minerva Ramos, ADA Ramos, and Officer Dennis Morales Rodriguez for alleged violations of their Fourth Amendment rights, claiming a civil rights conspiracy to detain and prosecute them without warrants or probable cause. They seek compensatory and punitive damages under 42 U.S.C. § 1983 and invoke the court's supplemental jurisdiction over claims under Puerto Rico law, including the Commonwealth's Constitution and Article 1802 of the Civil Code. The court is considering Defendants' motions for summary judgment alongside Plaintiffs' responses. After reviewing the motions, evidence, and applicable law, the court has denied the Defendants' motions. Under Rule 56 of the Federal Rules of Civil Procedure, the court must grant summary judgment if there is no genuine dispute regarding any material fact. The initial burden rests on the movant to demonstrate that there are no material facts in dispute, which, if satisfied, shifts the burden to the non-movant to present competent evidence to create a factual dispute. The factual background indicates that Plaintiffs, hired by a bail bond company, traveled to Puerto Rico to locate Ricardo Rodriguez Tirado, who had skipped bail. They apprehended him on May 5, 2011, after registering their firearms and collaborating with an off-duty officer. Following the apprehension, Rodriguez's mother contacted attorney Jose Fernandez Irizarry, who involved ADA Ramos. Plaintiffs claim that ADA Ramos instigated actions leading to their arrest, including advising Rodriguez's mother to file a complaint and instructing police to prevent the Plaintiffs from departing. ADA Ramos communicated with PRPD Officer Jesus A. Morales about Ms. Tirado's upcoming visit, requesting a criminal complaint to be drafted. Later that day, Ms. Tirado visited the San Sebastian police station and signed the complaint. Officer Dennis Morales, assigned to the Homicide Division in Aguadilla, then took over the case. While the Plaintiffs were waiting for their flight, they received a call from Officer Morales warning them of impending criminal charges. When the Plaintiffs went to the Aguadilla Police Station to address the situation, they were arrested and charged with kidnapping, aggravated assault, and possession of firearms. Officer Morales indicated that orders were coming from higher authorities. On May 6, the Plaintiffs were taken before a magistrate, who found probable cause for their arrest and placed them under house arrest until the criminal proceedings concluded. A preliminary hearing held 45 days later resulted in no probable cause for the charges against Dominguez and Fernandez, a decision that the prosecution appealed, which the Plaintiffs attribute to ADA Ramos. The court ultimately dismissed all charges against them on September 27, 2011. Regarding compliance with Local Rule 56, it requires a non-movant's opposing statement of material facts to admit, deny, or qualify the facts supporting a summary judgment motion, with proper citations. Plaintiffs’ opposing statements did not fully comply, as many qualifications and denials included additional facts that should have been in a separate section. Despite this, their opposing statements presented competent evidence that created uncertainty regarding the Defendants' facts and were vital to their claims. Chief Judge Gustavo A. Gelpí noted that while the court could disregard improperly provided facts, it values access to justice and hesitates to overlook these additional facts due to the serious justice access issues in Puerto Rico. Plaintiffs' statements are crucial in assessing the existence of genuine factual disputes, although not all conflicts necessitate a trial. The court will focus on material facts that could influence the case outcome. It is agreed that Plaintiffs traveled to Puerto Rico with firearms, but discrepancies arise regarding the timeline and manner of firearm registration. ADA Ramos claims both plaintiffs checked their firearms under Dominguez's name at the airport, citing his status as a retired policeman. In contrast, Plaintiffs assert they registered their firearms with a PRPD officer upon arrival on May 4, presenting their IDs and bail bond documents, which led to the officer allowing them to carry their firearms. Officer Morales supports the assertion that retired law enforcement can transport firearms across state lines. However, despite this clearance, he later searched their vehicle and seized the firearms. ADA Ramos contends she did not communicate with anyone about extradition matters, but Plaintiffs provide deposition testimony from Olga Martinez indicating otherwise, suggesting ADA Ramos had spoken with attorney Irizarry. Additionally, Officer Morales' sworn statement aligns with Plaintiffs' account, stating that ADA Ramos directed the arrest and charges against them. Questions remain regarding who initiated the arrest and the decision to file charges, with ADA Ramos indicating that a phone call from Plaintiff Fernandez to co-defendant Dennis Morales informed them of a kidnapping charge against them, which was confirmed by Morales on arrest, stating he was acting on ADA Ramos' instructions. ADA Ramos asserts that she was contacted by ADA Belinda Brignoni the day after arrests made by bounty hunters in Puerto Rico, claiming she was not involved until after Brignoni ordered the filing of criminal charges against the Plaintiffs. However, the Plaintiffs dispute this narrative, citing Olga Martinez's deposition where she states that ADA Ramos made the decision to file charges. Officer Jesus Morales’ sworn statement supports the Plaintiffs, indicating that ADA Ramos instructed him to file a kidnapping complaint against the Plaintiffs for arresting Mr. Rodriguez without following the extradition process. During their conversation, ADA Ramos noted Mr. Rodriguez's criminal record and an existing arrest warrant. Regarding Brignoni, on May 5, 2011, Officer Morales informed her of the earlier events, and she claims that ADA Ramos directed police to consider the Plaintiffs’ actions illegal and to prepare a report for Ms. Tirado’s arrival. Brignoni also indicated that ADA Ramos contributed to the decision to charge the Plaintiffs with kidnapping and firearm-related offenses. Despite other prosecutors being involved, Brignoni was responsible for court appearances. The investigation led by Officer Morales, which included interviews with multiple parties, is challenged by the Plaintiffs, citing Brignoni’s deposition that questions Morales' investigative steps and the establishment of probable cause. The court finds that the conflicting accounts presented by both parties raise significant issues regarding the legality of the Defendants' actions, the adequacy of the investigation before the arrests, and the existence of probable cause for both the warrantless arrests and the subsequent criminal charges. These contradictions support reasonable inferences of a potential conspiratorial agreement among the Defendants to infringe upon the Plaintiffs' Fourth Amendment rights. Section 1983 provides a remedy for constitutional rights deprivations under state action. To succeed in a Section 1983 claim, plaintiffs must demonstrate three components: (1) a deprivation of a right, (2) a causal link between the actor and the deprivation, and (3) state action. Additionally, plaintiffs must establish the connection between each defendant and the alleged federal right violation. For claims of civil rights conspiracy under Section 1983, plaintiffs must prove a combination of individuals acting in concert to commit an unlawful act or a lawful act through unlawful means, including an agreement to inflict harm and an overt act causing damages. Dominguez and Fernandez allege violations of their Fourth Amendment rights due to wrongful detention and prosecution without probable cause. The court previously identified this situation as one where false arrest, false imprisonment, and malicious prosecution claims coalesce into a conspiracy to maliciously prosecute. False arrest and false imprisonment claims arise from unlawful detentions without legal process. Under Puerto Rico law, false imprisonment claims require proof that the individual performing the arrest lacked reasonable cause to believe a felony occurred. Courts assess the reasonableness of the arresting officer's actions, imposing liability when negligence is present alongside a mistaken arrest. Malicious prosecution claims arise after false imprisonment ends, focusing on the wrongful initiation of legal proceedings. To succeed in such claims under Puerto Rico law, plaintiffs must show that defendants instigated a criminal action that concluded favorably for the plaintiff, acted with malice and without probable cause, and that the plaintiff incurred damages. The plaintiff must demonstrate both malice and lack of probable cause. A 1983 conspiracy claim for malicious prosecution can arise before a victim's arrest and includes the arrest itself. The court previously determined that a conspiracy involving fabricated evidence, false imprisonment, and malicious prosecution is a valid claim under Section 1983. Defendants claim that Plaintiffs lack evidence of a conspiratorial agreement for their arrest and prosecution. However, the court disagrees, particularly regarding Officer Morales' motion for summary judgment, which is based on the assertion of probable cause. Officer Morales contends that the Plaintiffs' claims fail due to probable cause supporting their arrests and prosecution. Conversely, Plaintiffs assert they were arrested without probable cause and endured both immediate imprisonment and prolonged house arrest pending criminal proceedings. The determination of probable cause in this context relies on whether an officer's knowledge would lead a reasonable person to believe a suspect committed an offense. The court finds that the disputed facts prevent a conclusion that probable cause existed at the time of arrest. Specifically, while both Plaintiffs were charged with illegal firearm possession, Officer Morales acknowledged that Plaintiff Dominguez could legally carry a firearm. The record indicates that Officer Morales did not verify whether Plaintiff Fernandez was legally allowed to carry a firearm, despite being misled by an on-duty officer. Viewing the facts favorably for the Plaintiffs, the court concludes that Officer Morales lacked probable cause for the firearm charges. This absence of probable cause allows the Plaintiffs to proceed with their claims against him, as a lack of probable cause for one charge does not negate a malicious prosecution claim based on another charge for which probable cause is absent. Consequently, Officer Morales' argument for summary judgment on these grounds is denied. ADA Ramos argues for the dismissal of Plaintiffs' claims based on the alleged lack of evidence for malicious intent or bad faith. However, the court finds her argument insufficient, noting that Plaintiffs’ 1983 claims address actions prior to the arrest, and that malice, defined as any unjustifiable motive, can be inferred from a lack of probable cause. The court concludes that Plaintiffs have raised factual uncertainties regarding malicious prosecution, denying ADA Ramos' motion to dismiss on this ground. Regarding prosecutorial immunity, the court explains that absolute immunity protects prosecutors for actions intimately related to the judicial process, including initiating and pursuing criminal prosecutions, regardless of malicious intent. Although ADA Ramos claims she is absolutely immune, she also contends she was not acting as a prosecutor at the relevant times, which the court finds untenable. As Plaintiffs do not seek damages for actions performed in her prosecutorial capacity, the court denies her request for dismissal based on absolute immunity. In terms of qualified immunity, the court notes that it is designed to protect public officials from liability for mistaken judgments. Although Defendants raised this doctrine early in the proceedings, insufficient factual development precluded a determination of the objective reasonableness of their actions. The court denied qualified immunity at that stage but allowed for re-evaluation later. The qualified immunity assessment involves two steps: first, determining whether the facts, viewed favorably to the opposing party, indicate a constitutional violation; second, assessing whether the violated right was clearly established at the time of the conduct. The second step is further divided into identifying controlling authority or a consensus of cases indicating that the conduct would violate a constitutional right, and whether a reasonable officer would have recognized this violation. The record indicates that the first prong of the inquiry regarding the deprivation of the Plaintiffs' Fourth Amendment rights is met. Examining the facts favorably to the Plaintiffs, there is potential support for their claims against both Defendants. Officer Morales argues for qualified immunity based on his assertion that the Plaintiffs' warrantless arrests were justified by probable cause. However, the Plaintiffs contend there are factual disputes concerning probable cause, which undermine the conclusion of objective reasonableness of Morales' actions. They highlight inconsistencies in witness statements gathered by Morales and note that he disregarded leads provided by the Plaintiffs about their firearms, despite having their contact information and purpose of visit. Additionally, they assert that Morales displayed obstinacy in interactions with them, claiming adherence to instructions from ADA Ramos. The court emphasizes that the standards for probable cause and qualified immunity differ, with qualified immunity requiring a lesser showing. The lack of comprehensive briefing on this matter limits the analysis. The Plaintiffs have presented sufficient factual disputes regarding Morales' involvement, necessitating that the probable cause issue be submitted to a jury. Consequently, the court denies the Defendants' motions for summary judgment regarding the Plaintiffs' claims against Officer Morales. The Plaintiffs allege that the Defendants conspired to detain and prosecute them without proper warrants or probable cause, seeking compensatory and punitive damages under 42 U.S.C. § 1983, along with invoking the court's supplemental jurisdiction for related Puerto Rico law claims. The court, after reviewing the motions and applicable law, denies the Defendants' summary judgment motions. Under Rule 56 of the Federal Rules of Civil Procedure, a motion for summary judgment should be granted only if there is no genuine dispute regarding any material fact, and the movant is entitled to judgment as a matter of law. A properly supported motion shifts the burden to the nonmovant to demonstrate a genuine factual dispute, requiring the nonmovant to identify competent evidence that could create a jury question. At the summary judgment stage, the court examines the entire record, viewing facts favorably for the nonmovant and allowing reasonable inferences while disregarding unsupported allegations. The court cannot make credibility determinations or weigh evidence, as those tasks are reserved for a jury. In the factual background, Mr. Ricardo Rodriguez Tirado skipped bail in New Jersey and fled to Puerto Rico, prompting the bail bond company, Speedy Bailbonds, to hire bounty hunters Dominguez and Fernandez to locate him. On May 4, 2011, they arrived in Puerto Rico, registered their firearms, and began their search, eventually meeting off-duty police officer Angel Diaz for assistance. The next day, they located and apprehended Rodriguez at his mother’s house. After the apprehension, Rodriguez asked his mother to contact his attorney, Jose Fernandez Irizarry. Following this, attorney Irizarry sought help from prosecutor ADA Ramos, who advised filing a complaint against the bounty hunters and instructed police to prevent their departure from the jurisdiction. Subsequently, Ms. Tirado filed the complaint at the San Sebastian police station, leading to the involvement of Officer Dennis Morales, who was assigned to the Homicide Division and was near the airport. Plaintiffs were warned by Officer Morales of impending criminal charges while waiting for their flight, prompting them to visit a local police station in Aguadilla. Instead of resolving the situation, they were arrested and charged with kidnapping, aggravated assault, and firearm possession. They were held overnight, and Officer Morales indicated that the orders came from higher authorities. On May 6, a magistrate found probable cause for arrest and imposed house arrest until the criminal proceedings concluded. A preliminary hearing 45 days later resulted in a no probable cause finding for two of the plaintiffs, Dominguez and Fernandez. The prosecution appealed this decision, attributed to ADA Ramos, but a reviewing court upheld the no probable cause determination on August 26, 2011. The charges were officially dismissed on September 27, 2011. In terms of procedural compliance, Local Rule 56(c) requires opposing parties to admit, deny, or qualify facts supporting a motion for summary judgment, with specific record citations for any denials or qualifications. The district court has discretion to accept the moving party's facts if the opposing party improperly controverts them. Although plaintiffs' opposing statements were not fully compliant with Local Rule 56(c), as they included additional facts improperly, they were nonetheless supported by competent evidence that raised uncertainty regarding the defendants' claims, which are vital to the plaintiffs' case. Chief Judge Gustavo A. Gelpí's remarks highlight the court's discretion regarding the consideration of facts not explicitly referenced in the parties' statements, as established by Local Rule 56. The court recognizes the importance of access to justice in Puerto Rico and is reluctant to disregard additional facts presented by the plaintiffs. The court will evaluate whether these opposing statements reveal genuine issues of material fact, noting that not all factual disputes require a trial. The case involves plaintiffs who traveled to Puerto Rico with firearms, with differing accounts of the registration process at the airport. One account states that both plaintiffs checked their firearms using the identification of one plaintiff, Dominguez, a retired policeman, while the plaintiffs claim they registered their firearms with a police officer upon arrival. Despite initial approval to carry their firearms, both were later searched, and the firearms were seized, leading to charges under Puerto Rico's Weapons Act. Additionally, there is a dispute regarding communication about extradition proceedings, with ADA Ramos asserting she did not speak with any representatives about the matter, while the plaintiffs provide deposition testimony suggesting that Ramos did communicate with attorney Irizarry before transferring the call to another official. The court will identify material facts that could impact the case's outcome. Officer Jesus Morales' sworn statement supports the assertion that after Irizarry spoke with ADA Ramos, she directed the San Sebastian Police Station to proceed with the arrest and charges against the Plaintiffs. Questions arise regarding who ordered the arrest and initiated the charges. ADA Ramos indicated that on the night of May 5, Plaintiff Fernandez was informed by co-defendant Dennis Morales of a pending kidnapping charge. The Plaintiffs claim Officer Morales stated the charges were based on directives from ADA Ramos, which he reiterated during their arrest. Conversely, ADA Ramos claims she was contacted the next day by ADA Brignoni about the situation and states she was not involved until after charges were already ordered by Brignoni. The Plaintiffs contest this narrative, citing testimony from Olga Martinez that implicates ADA Ramos in the decision-making. Additionally, Officer Morales' statement reveals that ADA Ramos instructed him to file a kidnapping complaint, asserting that the Plaintiffs had not followed proper extradition procedures. On the night of the incident, Officer Morales informed Prosecutor Belinda Brignoni about the developments, and she asserted that ADA Ramos declared the Plaintiffs' actions illegal, instructing the officers to prepare a report. Brignoni acknowledges that while other prosecutors were involved, she was responsible for court appearances related to the formal charges against the Plaintiffs, which included kidnapping and firearm-related offenses. Officer Morales, working the evening shift, took over the investigation upon receiving the initial complaint, interviewing multiple parties, including the Plaintiffs. However, the Plaintiffs have presented evidence, particularly from Brignoni's deposition, that challenges the adequacy of Officer Morales' investigation and the establishment of probable cause for the arrests. The court concludes that there are triable issues of fact regarding ADA Ramos' involvement in the case. Testimony undermines Officer Morales' claim of consulting with Prosecutor Brignoni prior to detaining Plaintiffs overnight. A review of the case record reveals conflicting narratives from both parties regarding key facts, which challenge the legality of the Defendants' actions, the adequacy of their investigations before arrests, and the presence of probable cause for those warrantless arrests. The court, favoring the non-moving party's perspective, finds reasonable inferences supporting allegations of a conspiratorial agreement among the Defendants to violate Plaintiffs' Fourth Amendment rights. Plaintiffs' claims are based on Section 1983, which provides a remedy for constitutional violations by state actors. To succeed, they must demonstrate a deprivation of rights, a causal link between the actor and the deprivation, and state action. Additionally, they need to establish the connection of each defendant to the violation. Claims of civil rights conspiracy require proof of an agreement among two or more individuals to commit an unlawful act, accompanied by an overt act resulting in harm. Dominguez and Fernandez allege violations of their Fourth Amendment rights against unreasonable searches and seizures, asserting that Defendants initiated their detention and criminal prosecution without probable cause. The court previously recognized the unusual circumstances that allowed for claims of false arrest or imprisonment and malicious prosecution to support a conspiracy to maliciously prosecute. False imprisonment under Puerto Rico law is defined as unlawful detention, whether by law enforcement or others, executed without legal process, such as an arrest lacking a warrant or probable cause. In Soto-Cintron on behalf of A.S.M. v. United States, the court addressed the standards for false imprisonment claims under Puerto Rico law, emphasizing that such claims require the arresting individual to lack reasonable cause for believing a felony was committed. The court highlighted that evaluating the reasonableness of the defendant's actions involves assessing various factors, including the ages, experiences, and knowledge of both the defendant and the arrestee, as well as the seriousness of the alleged crime. Liability arises when the arresting officer's actions are deemed negligent. The court further explained the distinct tort of malicious prosecution, which occurs after the period of false imprisonment ends. To succeed in a malicious prosecution claim, a plaintiff must demonstrate that a criminal action was instigated by the defendants, that it concluded favorably for the plaintiff, that the defendants acted with malice and without probable cause, and that the plaintiff suffered damages. Malice is equated with bad faith under Puerto Rican law. Additionally, the court acknowledged the possibility of a conspiracy claim under § 1983 related to malicious prosecution, which encompasses actions leading up to and including the arrest. The viability of such claims is supported by allegations of fabricated evidence and false imprisonment. Defendants' motions for summary judgment were contested, as the court found that plaintiffs presented sufficient evidence to suggest a conspiratorial agreement regarding the arrests and prosecution of the bounty hunters, particularly concerning the claim of probable cause asserted by Officer Morales. Plaintiffs argue that their claims against Officer Morales are valid because they were arrested without probable cause, leading to both immediate imprisonment and subsequent house arrest. Officer Morales contends that probable cause supported the arrest, seizure, and prosecution of the Plaintiffs. The determination of probable cause hinges on whether the facts known to the officer would lead a reasonable person to believe that the suspect committed an offense, as established in Hartman v. Moore and Holder v. Town of Sandown. The standard is objective, evaluated from the perspective of a reasonable officer. Despite Morales's assertions, the facts surrounding the arrest raise significant doubts about the existence of probable cause. Evidence suggests that instructions from Assistant District Attorney Ramos and Prosecutor Brignoni, as well as assertions from Olga Martinez regarding the bounty hunters' actions, complicate any reasonable determination of probable cause by Officer Morales. Notably, both Plaintiffs were charged with illegal firearm possession, yet Plaintiff Dominguez, a former law enforcement officer, had the legal right to carry a firearm. Furthermore, Plaintiff Fernandez had registered his firearm at the airport, a fact Officer Morales failed to investigate adequately. In light of these circumstances, the court concludes that Officer Morales lacked probable cause—or even reasonable suspicion—for the firearm charges against the Plaintiffs. This lack of probable cause is sufficient for the Plaintiffs to proceed past summary judgment, as their claims can stand even if probable cause existed for other charges. Probable cause for one charge does not preclude a malicious prosecution claim for another charge where probable cause is absent, as established in Goddard v. Kelley. A malicious prosecution claim can succeed for certain offenses even if it fails for others. Officer Morales's argument that probable cause negates the claims against him is rejected, resulting in the denial of his summary judgment request. ADA Ramos contends that the plaintiffs failed to show malicious intent or bad faith, which she claims warrants dismissal of the charges against her. However, this argument is insufficient because malice is a necessary component of malicious prosecution, which can be inferred from a lack of probable cause. The plaintiffs' assertions create factual uncertainty regarding the officers' probable cause at the time of arrest, thereby denying ADA Ramos's request for dismissal. Prosecutors enjoy absolute immunity for acts closely tied to the judicial process, such as initiating and pursuing criminal prosecutions, even if those actions involve malice or corruption. However, when acting in an investigative capacity, prosecutors are only entitled to qualified immunity. ADA Ramos claims absolute immunity from suit, arguing her actions were part of the judicial process and that she was not acting as a prosecutor during the relevant events. However, the court finds this argument untenable as the plaintiffs do not seek damages for her prosecutorial duties. Consequently, Ramos' request for dismissal based on absolute immunity is denied. The doctrine of qualified immunity offers protection to public officials against liability under Section 1983 for reasonable mistakes in judgment. The court initially denied qualified immunity due to insufficient factual development regarding the objective reasonableness of the defendants' actions, allowing for a reevaluation during summary judgment. The qualified immunity analysis consists of a two-step process: first, determining if the facts, viewed in favor of the opposing party, establish a constitutional violation; second, assessing whether the violated right was clearly established at the time of the conduct. This second step involves identifying either controlling authority or a consensus of persuasive authority that indicates to a reasonable officer that their conduct would violate a constitutional right, examined within the specific context of the case. The records suggest the first prong is met, potentially indicating that the defendants violated the plaintiffs' Fourth Amendment rights. The court now addresses the second prong, where Officer Morales asserts no violation occurred due to probable cause supporting the warrantless arrests. The plaintiffs counter that factual disputes regarding probable cause prevent a conclusion on the objective reasonableness of the defendants' actions. Plaintiffs highlight significant contradictions in statements provided by witnesses interviewed by Officer Morales during his investigation. They emphasize that Officer Morales disregarded a lead regarding their firearms, despite having their contact information and the purpose of their visit. Plaintiffs assert that Officer Morales displayed obstinacy in his interactions with them, claiming he was following instructions from ADA Ramos. The court observes that the parties have not addressed the differing reasonableness standards relevant to probable cause and qualified immunity. The court notes that qualified immunity requires a lower standard of proof. The lack of thorough legal briefing hinders the analysis, as litigants are obligated to articulate their arguments clearly. Plaintiffs have presented enough factual disputes concerning Morales's involvement, warranting a jury's consideration of probable cause. The court references prior cases establishing that a genuine dispute over material facts prevents summary judgment on probable cause and qualified immunity. ADA Ramos argues for qualified immunity, asserting that she was not involved in the arrest or decision to pursue charges, claiming her role was limited to providing an official legal opinion on bounty hunters. Both Ramos and Morales argue that the legal standards regarding bounty hunters in Puerto Rico are not clearly established. However, the court emphasizes that the critical issue is whether Plaintiffs had a Fourth Amendment right to be free from unreasonable searches and seizures, rather than their rights as bounty hunters. Fourth Amendment rights regarding seizure based on probable cause and protection against arrest or criminal proceedings based on false evidence were well established at the time of the alleged misconduct. Relevant case law highlights that defendants were required to have probable cause for warrantless arrests. The court determined that the plaintiffs’ claims substantiate a constitutional violation, leading to the denial of the defendants' request for summary judgment based on qualified immunity. Regarding supplemental state law claims under Article 1802 and the Puerto Rico constitution, the defendants sought summary judgment, assuming the federal claims would be dismissed. However, since the federal claims survived, so did the state claims, resulting in the denial of the defendants’ request for summary judgment on these grounds. The court emphasized that granting summary judgment is inappropriate when material facts are contested. Summary judgment is permissible only when there is no genuine dispute over material facts, as per Federal Rule of Civil Procedure 56(a). Therefore, the defendants' motions for summary judgment were denied. Additionally, the plaintiffs’ complaint included other claims that have been dismissed, leaving only the Section 1983 claims against ADA Ramos and Officer Morales. The court clarified procedural details regarding the review of probable cause determinations under Puerto Rico law, noting that genuine disputes over material facts persist in the record. An outstanding warrant from New Jersey against Rodriguez was communicated to the caller, with New Jersey indicating a limited intent to extradite from surrounding states. The Supreme Court recognizes that false arrest and false imprisonment are overlapping torts, with the court choosing to refer to them collectively as false imprisonment. Under Puerto Rico law, these claims share identical elements. The court will address the defendants' summary judgment arguments without a specific order and finds that precedents related to malicious prosecution are relevant to the Section 1983 conspiracy claims made by the plaintiffs. If there are disagreements among the parties, they may request additional briefing, but the court will not undertake the counsel's responsibilities. Arguments presented by ADA Ramos based on probable cause are rejected, emphasizing that legal definitions must be specific to the facts of each case. The court notes that neither party presented a more specific right relevant to the case, which is crucial for the analysis. The qualified immunity determination is denied without prejudice, and the parties are advised to review the First Circuit’s decision in Rodriguez-Tirado v. Speedy Bail Bonds, which pertains to bounty hunters' authority.