Binti Watts and Christopher Pryor v. County of Sacramento, a Municipal Corporation Lorie Timberlake Bryan Munn Donald Black and Jeffrey Morace

Citations: 256 F.3d 886; 2001 Cal. Daily Op. Serv. 5962; 2001 Daily Journal DAR 7351; 2001 U.S. App. LEXIS 15801; 2001 WL 792537Docket: 00-15099

Court: Court of Appeals for the Ninth Circuit; July 16, 2001; Federal Appellate Court

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Plaintiffs Binti Watts and Christopher Pryor filed a lawsuit against the County of Sacramento and several Sheriff's deputies under 42 U.S.C. § 1983, claiming unlawful entry into their home and wrongful arrest. The case arose after an anonymous tip suggested that murder suspect Chris Burgess was at their residence. Despite the arrest warrant listing a different address for Burgess, officers acted on the tip. After receiving a dispatch confirming Burgess's description and potential location, Sergeant Munn and a team of officers approached the plaintiffs' home. Officer Morace, with his gun drawn, confronted Pryor, who fit the suspect's description. Following Pryor's acknowledgment of his name, Morace allegedly used excessive force against him. The district court granted summary judgment to the defendants on the Fourth Amendment claims and dismissed state tort claims, leaving only the issue of illegal search for jury consideration. The Ninth Circuit Court of Appeals has jurisdiction and has reversed the district court's decision.

After handcuffing Pryor, Officer Morace seated him in a kitchen chair while Officers Timberlake and Black conducted a protective sweep of the residence. Timberlake found Watts, who was instructed to awaken her children, and they were escorted to a bedroom under guard. Sergeant Munn obtained Pryor's identification, which was found to be valid. Officers noted that Pryor lacked the tattoos associated with the suspect, Burgess. After approximately thirty to forty-five minutes, Pryor was released from handcuffs and informed of the mistake, while the officers took a photograph from the house.

The plaintiffs initiated legal action, and the defendants sought summary adjudication of the Section 1983 claims and state claims for false arrest and false imprisonment. The district court granted summary judgment for the defendants regarding the Section 1983 claims against the County of Sacramento, the individual defendants for illegal entry and detention, and Watts's state claims. 

A jury trial on the remaining claim regarding the search of the residence resulted in a verdict for the defendants, leading to a judgment that the plaintiffs appealed. The central issue was whether an anonymous tip about a murder suspect, combined with police observations, justified the officers' belief that the suspect resided at the plaintiffs' home, thereby legitimizing their entry under an arrest warrant for Chris Burgess. 

The district court determined that an arrest warrant provided sufficient authority for the officers to enter Pryor's home if they had reason to believe the suspect was present there. It dismissed claims of illegal entry and detention against Pryor and Watts, stating that the officers had reasonable belief about Pryor's co-residency based on the anonymous tip and his appearance. The court concluded that the tip and Pryor answering the door in boxer shorts while responding to "Chris" met the probable cause standard. 

Citing *Payton v. New York*, the court affirmed that an arrest warrant allows entry into a dwelling if there is reason to believe the suspect is inside. Additionally, in *Steagald v. United States*, it was established that officers cannot enter a third party's home without exigent circumstances or consent, even if they reasonably believed the suspect might be present. Thus, the court noted that the officers' search lacked the necessary judicial oversight, making it unreasonable from the perspective of the homeowner.

If the suspect named in an arrest warrant is a guest at a third party's dwelling, police must secure a search warrant to respect the third party's Fourth Amendment rights, unless exigent circumstances exist. Conversely, if the suspect is a co-resident, the principles from Steagald do not apply, and under Payton, officers may arrest the suspect and use any evidence found against the third party, provided they have reasonable belief that the suspect resides and is present in the home at the time of entry.

Determining whether officers had reasonable belief about a suspect's co-resident status involves mixed questions of law and fact. In the case of plaintiff Pryor, the court could not conclude that it was reasonable for officers to believe he was the suspect, Burgess, thus summary judgment on Pryor's illegal entry and detention claims was deemed inappropriate.

For Watts's illegal entry claim, substantial evidence is required to reasonably believe that a suspect resides with a third party. Previous cases demonstrated that significant corroborative evidence must support such a belief. In Watts's situation, the anonymous tip lacked verification, and the sheriff's department failed to substantiate the connection between the address provided by the tipster and Burgess. Therefore, Pryor's mere presence at his girlfriend's home did not suffice to establish reasonable belief regarding his residency. The court reversed the summary adjudication of Watts's unlawful entry claim as erroneous.

Appellants contend the district court incorrectly dismissed Watts's state law claims for false arrest and imprisonment. Under California law, false arrest is a form of false imprisonment, with a valid claim arising from an unlawful arrest followed by imprisonment. The officers detained Watts unlawfully after entering the residence and handcuffing Pryor. Their safety concerns did not justify this infringement on Watts's liberty, indicating the district court should have upheld her false-imprisonment claim.

Regarding municipal liability under Section 1983, a municipality can be held accountable if a government employee acted under a formal policy or longstanding custom. A claim can survive a motion to dismiss even if it only alleges that the officers' conduct aligned with official policy. The district court's conclusion that it need not assess municipal liability due to its findings on the merits of the Section 1983 claims is flawed; thus, the claim must be remanded for further evaluation.

Since the summary judgment favoring defendants on the Section 1983 claims is reversed, the district court also erred in instructing the jury that Pryor's arrest was lawful, rendering the verdict void and necessitating a remand for trial. Consequently, the judgment is REVERSED and REMANDED.