Estrada

MEMORANDUM **

Lorraine Estrada (“Estrada”) was arrested for puncturing the ear of her flaneé during a fight in their home in violation of California Penal Code § 273.5 (“ § 273.5”). She brought suit against the County of Los Angeles (“County”) and the officers involved, claiming that they arrested her without probable cause and used excessive force in effectuating the arrest and in later handcuffing her to transfer her to a medical facility. The district court granted summary judgment with respect to all claims and all parties, with the exception of officer Joseph Knott. After a short trial, the jury found in favor of Knott, and the district court subsequently denied Estrada’s motion for a new trial. Estrada now appeals the grant of summary judgment and the denial of the motion for a new trial.

I. Probable Cause

As the district court concluded, “[this] issue is not close.” Probable cause is established when, under the totality of the circumstances known to the police officers at the time, a reasonably prudent police officer would conclude, based on his training and experience, that there was a fair probability that the suspect has committed or is committing an offense. Michigan…