Cassette

MEMORANDUM *

I. Section 1983, False Arrest, Emotional Distress Claims

Jill Cassette’s § 1983 claim for a Fourth Amendment violation, as well as *586 her state law claims for false arrest and intentional infliction of emotional distress, fail because the King County Sheriffs Department had probable cause to search her house and to arrest her on suspicion of helping to run the Seattle Garden of Eden prostitution ring.

Police Detective Draper did not include every piece of information in his affidavit supporting the search warrant. Yet the district court correctly ruled that the omissions had no effect on the proper determination of probable cause. First, Draper included sufficient information to show the likely bias of the informant. Inclusion of the informant’s direct quotations would have had only a marginal and cumulative impact on that showing; it would not have revealed any new information. The omission accordingly was not material. There was also no error in the district court’s conclusion that, even if all evidence of bias was considered, it was not sufficient to overcome the indicia of the informant’s reliability because of the informant’s firsthand knowledge and outside…