U.S. Court of Appeals Affirms Summary Judgment for Police Officers in False Arrest Case


Attorney Courtney Mayo successfully obtained affirmation of summary judgment from the United States Court of Appeals, First Circuit, in connection with a complaint alleging area police officers violated plaintiff’s civil rights during an arrest for multiple vehicle-related infractions.

The plaintiff filed suit against multiple police officers alleging that the officers committed civil rights violations following a traffic stop which led to plaintiff’s arrest for operating an unregistered motor vehicle without a driver’s license.  The plaintiff alleged false imprisonment, harassment and conspiracy by police officers.  Several weeks prior to his arrest, the plaintiff had received a citation from officers for the same infractions.

Attorney Mayo filed a Motion to Dismiss arguing that the plaintiff’s Complaint lacked any factual statement for which relief could be granted.  Further, Attorney Mayo argued that the town could not be held liable for tortious conduct by its officers.  Moreover, Mayo argued that the claim for false imprisonment was without merit as the plaintiff was not confined or arrested during the first traffic stop and that the arresting officer had legal justification for the arrest following the second traffic stop.  The plaintiff admitted that he was driving without a driver’s license and with an unregistered vehicle.  Lastly, Attorney Mayo pointed to the lengthy procedural history of the case, pointing out that the plaintiff had filed numerous similar actions and vexatious filings against the municipal defendants.  The plaintiff opposed the motion and filed his own Motion for Summary Judgment.  Prior to these filings, the plaintiff had voluntarily dismissed two previous civil actions filed against the officers related to the same incidents.

The Court converted the Motion to Dismiss into one for Summary Judgment and found in favor of the Town and its Officers.  In addition to affirming the district court’s memorandum and order granting summary judgment for the municipal defendants, the U.S. District Court of appeals added that the plaintiff’s claims against the defendants were barred by Federal Rules of Civil Procedure 41(a)(1)(B)’s “two-dismissal rule” because the plaintiff had voluntarily dismissed prior civil actions filed against the defendant arising from same events and therefore the dismissal served as an adjudication on the merits. Accordingly, the U.S. Court of Appeals entered judgment in favor of the municipal defendants.

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