By Marcus Fields
Today, in Pleasants v. Rigsby, an unpublished decision, the Fourth Circuit affirmed the District Court for the Western District of Virginia’s grant of summary judgment in favor or Officer Robert Rigsby and the Town of Louisa on Sloan Pleasants’ claim that Rigsby falsely arrested her.
Officer Rigsby’s Arrest of Sloan Pleasants
On December 13, 2009, at the request of Sloan Pleasants’ ex-husband Kevin, Officer Rigsby went to the house of Sloan Pleasants in order to perform a “welfare check” on Kevin’s eleven-year-old daughter. During the visit the child was visibly frightened and Sloan Pleasants initially refused to let the child speak with either Kevin or Officer Rigsby. Upon questioning, the child told Officer Rigsby that Sloan had slapped her on her thigh and pulled her by her wrists. Officer Rigsby could see no visible marks or bruises. Officer Rigsby then proceeded to arrest Sloan Pleasants for assault and battery against a family member, a charge that was later dropped.
Pleasants’ Claims on Appeal
Pursuant to 42 U.S.C. § 1983, Pleasants originally claimed unlawful entry, false arrest, malicious prosecution, and failure to train on the part of the Town of Louisa, as well as other related state law claims. These claims were dismissed by the district court, and all but one of these dismissals were affirmed by the Fourth Circuit in an earlier appeal. The false arrest claim was remanded to the District Court for further proceedings. After further developing the factual record the District Court granted summary judgment for Officer Rigsby after finding that he was entitled to qualified immunity. Pleasants appealed, claiming the District Court erroneously based this finding on “disputed facts and inferences drawn in favor of Officer Rigsby.”
Officer Rigsby Entitled to Qualified Immunity
The Fourth Circuit, reviewing the district court’s grant of summary judgment de novo, determined that the district court was correct in granting Rigsby qualified immunity. Government officials are protected by the doctrine of qualified immunity “from liability for civil damages insofar as their conduct does not violate clearly established statutory or constitutional rights of which a reasonable person would have known.” In order to find that qualified immunity is not present, a court must conclude that “a constitutional violation occurred and … the right violated was clearly established.” Both the district court and the Fourth Circuit focused analysis on the second prong. The Fourth Circuit ultimately concluded that based on the frightened state of the eleven-year-old girl, the girl’s statements to Officer Rigsby, and Sloan Pleasants’ demeanor towards Officer Rigsby, “a reasonable officer could have believed that Officer Rigsby’s arrest of Pleasants was lawful.”
Grant of Summary Judgment Affirmed
For the above reasons, the Fourth Circuit affirmed the grant of summary judgment to Officer Rigsby on the false-arrest claim.