George Lopez Ramirez v. City of Glendale

Good Law
United States Court of Appeals for the Ninth CircuitMarch 10, 202221-55036California267 words

Opinion

Opinion

facts establish probable cause for Plaintiff’s arrest for domestic battery.

Because there was probable cause to arrest Plaintiff for domestic battery, we

need not address whether there was also probable cause to arrest him for the

outstanding warrant. See United States v. Magallon-Lopez, 817 F.3d 671, 675 (9th

Cir. 2016) (“[I]f the facts support probable cause to arrest for one offense, the arrest

is lawful even if the officer invoked, as the basis for the arrest, a different offense as

3 to which probable cause was lacking.”). Nor need we address whether the officers

are entitled to qualified immunity.

2. Post-arrest detention. The district court did not err in granting summary

judgment to Defendants on Plaintiff’s Fourteenth Amendment claim. Detention on

a mistaken warrant may violate due process if “the circumstances indicated to the

defendants that further investigation was warranted.” Garcia v. County of Riverside,

817 F.3d 635, 640 (9th Cir. 2016) (citation omitted). However, probable cause for

an arrest defeats any subsequent claim for unlawful imprisonment under § 1983. See

Cabrera v. City of Huntington Park, 159 F.3d 374, 380 (9th Cir. 1998) (“To prevail

on…

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