Daniel Serrano v. Russell Sanders

facts is correct and drawing all reasonable inferences in that party’s favor. See Peck, 51 F.4th at 887. We do not have jurisdiction to entertain any challenge to the district court’s conclusion that the evidence is sufficient to support Serrano’s view of the facts or that the disputes of fact identified by the district court are genuinely disputed. See id. 2 We use the term “unlawful arrest” to include Serrano’s unreasonable seizure claim under the Fourth Amendment and his false arrest and false imprisonment claims under Washington state law. See Youker v. Douglas County, 162 Wash. App. 448, 465 (2011). The existence of probable cause is a complete defense to each of these claims, see Atwater v. City of Lago Vista, 532 U.S. 318, 354 (2001); Hanson v. City of Snohomish, 852 P.2d 295, 301 (Wash. 1993) (en banc), and it is the sole basis on which Trooper Sanders seeks to justify Serrano’s warrantless arrest. Because the claims rise and fall together, we analyze them as one under the general label “unlawful arrest.”

2 officer might be liable under these claims. See Pearson v. Callahan, 555 U.S. 223,

232 (2009) (“[A] court must decide whether the facts that a plaintiff has . . .…