Trobaugh v. Melton, Civil No. 2:15-CV-00005

RICKY N. TROBAUGH, Plaintiff, v. W.B. MELTON, et al. Defendants.

Civil No. 2:15-CV-00005

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF TENNESSEE NASHVILLE DIVISION

May 27, 2016

Judge Sharp

MEMORANDUM

Plaintiff Ricky N. Trobaugh brings claims under 42 U.S.C. § 1983 for violations of the Fourth, Fifth, and Fourteenth Amendments to the U.S. Constitution. (Docket No. 1, pp. 6-10.) He also brings several state-law claims for alleged torts and violations of state statutes. (Docket No. 1, pp. 10-16.) Defendants Steve Hopper, Michael Agee, and W.B. Melton have filed two separate Motions for Summary Judgment (Docket Nos. 27, 30) as to all of Trobaugh's claims.

The Court will grant Defendants' Motions.

BACKGROUND

This case arose after Plaintiff's 2014 arrest. The following facts are undisputed.¹

Around 10 a.m. on February 17, 2014, Ricky Trobaugh was pulled over while driving in Overton County, Tennessee. (Docket No. 25, pp. 2-3.) The officer who stopped Trobaugh—an unnamed deputy with the Overton County Sherriff's Department, identified here only as "John Doe"—took Trobaugh's license back to his patrol car to run the license number through the National Crime Information Center ("NCIC") database. (Docket No. 25, p. 3.) The databaserevealed that there was an outstanding warrant for Trobaugh's arrest in Smith County, Tennessee. (Docket No. 25, p. 3.) According to the warrant, Trobaugh had failed to appear for a show-cause hearing in an unrelated case involving Trobaugh and Citizen's Bank. (Docket No. 25, p. 3.)

The deputy told Trobaugh about the warrant, but Trobaugh insisted that it was a mistake. The deputy checked the warrant information again. When Trobaugh's Social Security information matched the information in the NCIC database, the deputy arrested Trobaugh and took him to the Overton County Jail. (Docket No. 25, p. 3.)

Trobaugh was booked at the Overton County Jail at 10:26 a.m. (Docket No. 31, p. 3.) The Overton County deputy then called a deputy from the Smith County Sheriff's Department to arrange Trobaugh's transfer. Trobaugh, who was "very cooperative" with Overton County deputies, was not placed in a jail cell while he waited for the Smith County deputy to arrive. (Docket No. 31, p. 3.) Instead, he sat in the jail's booking area. (Docket No. 31, p. 3.)

Trobaugh's sister arrived at the Overton County Jail to post bond for Trobaugh;² while there, she told Melton that Trobaugh had a "bad heart." (Docket No. 31, p. 5.) Melton concedes that Trobaugh was not allowed to take medications while in custody, but points out that Trobaugh never showed any need for medical treatment that morning. (Docket No. 31, p. 5.) Still, Overton County Jail personnel wrote the phone number for Trobaugh's sister on a piece of paper and told Trobaugh to keep the paper in his shirt pocket in case he had any medical problems that day. (Docket No. 31, p. 5.) Trobaugh did not complain about any medical issues while he waited in the Overton County Jail. (Docket No. 31, p. 6.)

Michael Agee, a deputy with the Smith County Sheriff's Department, came to the Overton County Jail at 11:40 a.m. (Docket No. 31, p. 3.) He then drove Trobaugh to the Smith County Jail, in Carthage, Tennessee, where they arrived around 12:50 p.m. (Docket No. 31, p. 3.) (Docket No. 31, p. 3.) Trobaugh's sister got to the Smith County Jail soon afterwards. She paid a $500 bond, and Trobaugh was released at 1:07 p.m. (Docket No. 31, p. 3; Docket No. 32, ex. E.) All told, Trobaugh had spent about three hours in custody.

Two days later, the Smith County Circuit Court Clerk's Office received a letter from Citizen's Bank, notifying the Circuit Court that the bank had settled its suit with Trobaugh. (Docket No. 28-3.) Soon after receiving the letter, the Circuit Court dismissed the charges against Trobaugh and refunded his $500 bond payment. (Docket No. 31, p. 5.)

Trobaugh filed this lawsuit in January 2015. (Docket No. 1.)

LEGAL STANDARD

Summary judgment "is appropriate only where 'the pleadings, the discovery and disclosure materials on file, and any affidavits show that there is no genuine issue as to any material fact and that the movant is entitled to judgment as a matter of law.' " Whitfield v. Tennessee, 639 F.3d 253, 258 (6th Cir. 2011) (quoting Fed. R. Civ. P. 56(c)). A genuine issue exists "if the evidence is such that a reasonable jury could return a verdict for the nonmoving party." Anderson v. Liberty Lobby, 477 U.S. 242, 248 (1986). A court's function at the summary-judgment stage is simply to "determine whether there is a genuine issue for trial." Id. at 249. In doing so, a court must draw "all reasonable inferences in favor of the nonmoving party." Shreve v. Franklin Cty., 743 F.3d 126, 132 (6th Cir. 2014). See also Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 587 (1986).

ANALYSIS

Trobaugh brings three claims under 42 U.S.C. § 1983. (Docket No. 1, pp. 6-10.) He also brings six state-law tort claims and one claim for recovery under state statutes. (Docket No. 1, pp. 11-16.)

I. Federal Claims

Hopper, Agee, and Melton argue that qualified immunity shields them from Trobaugh's federal claims. The Court agrees.

In civil suits for money damages, government officials are entitled to qualified immunity for discretionary acts that do "not violate clearly established [federal] statutory or constitutional law." Anderson v. Creighton, 483 U.S. 635, 638-39 (1987). Qualified immunity is rooted in the premise that government officials should be free from the costs, burdens, and distractions of litigating unsustainable claims. See Crawford-El v. Britton, 523 U.S. 574, 578-79 (1998). When presented with a qualified immunity argument in a § 1983 action, a court must first determine whether the plaintiff has shown that "constitutional violation[s] occurred." Lyons v. City of Xenia, 417 F.3d 565, 571-72 (6th 2005).

Trobaugh has failed to show that Defendants violated any of his constitutional rights when they arrested and detained him. Defendants are therefore entitled to qualified immunity, and their Motions will be granted on each of Trobaugh's federal claims.

A. Trobaugh's Arrest

Trobaugh claims that Defendants violated his Fourth Amendment rights by arresting him without a valid warrant. Aside from the Complaint itself, Trobaugh has not offered any evidence in support of this claim.

A § 1983 false-arrest claim requires a plaintiff to prove that the arresting officer lacked probable cause to make the arrest. Fridley v. Horrighs, 291 F.3d 867 (6th Cir. 2002). For Trobaugh, that would require showing that the arrest warrant was invalid, since a valid arrest warrant is normally a complete defense to a federal constitutional claim for false arrest.³ Voyticky v. Vill. of Timberlake, 412 F.3d 669, 677 (6th Cir. 2005).

Trobaugh has not made this showing. Based on the record before the Court, Trobaugh was arrested pursuant to a lawfully-issued bench warrant. And an "arrest warrant[] in the hands of a police officer, unless facially invalid, [is] presumed valid," Fettes v. Hendershot, 375 Fed. App'x 528, 532 (6th Cir. 2010). Since Trobaugh never offered any evidence to dispute the warrant's validity, he cannot make out a constitutional claim for false arrest. Terrell v. City of Cleveland, 1987 WL 37477, at *2 (6th Cir. May 22, 1987) ("Plaintiff has not alleged a deficiency in the warrant for his arrest, and a facially valid warrant prevents [the plaintiff] from meeting the threshold requirement to prove a constitutional violation."); see also Thurmond v. Cty. of Wayne, 447 Fed. App'x 643, 648-49 (6th Cir. 2011) (finding that, when plaintiff was arrested pursuant to a facially valid warrant and did not challenge the facial validity of that warrant, plaintiff's arrest did not violate the Fourth Amendment's warrant requirement).

Trobaugh has failed to show a constitutional violation, so Defendants are entitled to qualified immunity on the false-arrest claim.

B. Trobaugh's Detention

Trobaugh claims that his detention amounted to "summary punishment without due process of law," particularly since he told custodial officers that he had done nothing wrong. (Docket No. 1, pp. 7-8.) Once again, Trobaugh offers no evidence to support this claim.

This claim is weak from the outset. Trobaugh was detained after a December 30, 2008 bench warrant appeared on an NCIC database; that warrant—as discussed above—was facially valid. It is well settled that mistaken detention pursuant to a facially-valid arrest warrant does not automatically violate the Due Process Clause. Baker v. McCollan, 443 U.S. 137, 145-46 (1979) (rejecting § 1983 claim of a plaintiff who was mistakenly detained on a valid warrant). And repeated protests of innocence are normally irrelevant to a due-process inquiry. After all, a "sheriff executing an arrest warrant is [not] required to investigate independently every claim of innocence," nor are custodial officers "required by the Constitution to provide an error-free investigation of such a claim." Id. at 145 (noting that officers are not obligated to heed a detainee's "repeated protests of innocence"); Patterson v. New York, 432 U.S. 197, 208 (1977) ("Due process does not require that every conceivable step be taken, at whatever cost, to eliminate the possibility of convicting an innocent person.").

Nevertheless, in rare cases, mistaken detention can be outrageous enough to amount to a due-process violation. Id. (noting that extended mistaken detention "will after the lapse of a certain amount of time deprive the accused of" his constitutional due process rights). Such cases usually involve fairly egregious facts. For instance, in Gray v. Cuyahoga County Sheriff's Department, 150 F.3d 579, 582-83 (6th Cir. 1998), the Sixth Circuit reversed a grant of summary judgment to a sheriff after the plaintiff presented evidence that he was detained forforty-one days even though the deputies had a photo of the person listed on the warrant; the Court noted that the photo ...