Schramm v. City Of New York

Background

The dispute arose from a traffic stop at about 1:30 a.m. on June 7, 2015. Robert Schramm was driving with Gabriela Saenz and James Farrell as passengers. Police stopped the vehicle at a sobriety checkpoint planned by traffic sergeant Noel Jugraj. The checkpoint used flashing lights and stopped every vehicle except taxis and livery cars.

An officer asked Schramm whether he had consumed alcohol. He denied drinking. Officers then directed him to pull over, asked him to exit the vehicle, and asked him to take a portable alcohol breath test. Schramm refused. After he turned toward the passengers and rolled his window nearly closed, officers arrested him for driving while impaired under New York Vehicle and Traffic Law § 1192(1).

Saenz also exited the vehicle. Officers repeatedly instructed her to step away from the arrest scene, but she refused and said she would stay with her husband. She was arrested for obstructing governmental administration under New York Penal Law § 195.05. The opinion also describes testimony that Saenz physically interfered with officers, although the court's probable-cause ruling relied on her refusal to follow the officers' instructions.

About three hours after the stop, Schramm's breath test showed a blood alcohol concentration of .034. The New York County District Attorney's Office declined to prosecute him. Saenz accepted an adjournment in contemplation of dismissal.

Claims and Procedural History

The amended complaint asserted claims for false arrest and wrongful imprisonment under the Fourth, Fifth, and Fourteenth Amendments and 42 U.S.C. § 1983; malicious prosecution; an unconstitutional sobriety checkpoint; procedural due process violations; and municipal liability against the City under Monell v. Department of Social Services. The plaintiffs voluntarily dismissed their malicious-prosecution and procedural-due-process claims.

After discovery, both sides moved for summary judgment. Summary judgment is a decision entered when the evidence shows no genuine dispute over a fact important to the outcome and one side is entitled to judgment under the law.

False-Arrest Claims

The court held that probable cause defeated the false-arrest claims. Probable cause means facts and circumstances that would lead a reasonably cautious officer to believe an offense had been committed.

As to Schramm, the court found probable cause to arrest him for driving while his ability was impaired by alcohol. The court relied on evidence that he had consumed alcohol, had bloodshot eyes, smelled of alcohol, denied drinking when asked, and acted evasively when asked to take a sobriety test. The court did not decide whether probable cause existed for the other offenses listed in his arrest report because probable cause for one offense was sufficient to defeat the false-arrest claim. The court also stated that, even if probable cause were lacking, the officers had at least arguable probable cause and therefore qualified immunity. Qualified immunity protects an officer when officers of reasonable competence could disagree about whether the conduct was lawful.

As to Saenz, the court held that officers had probable cause to arrest her for obstructing governmental administration because she repeatedly refused instructions to step away from the scene of Schramm's arrest. The court also found at least arguable probable cause and concluded that qualified immunity applied even if the officers' probable-cause determination were disputed.

Sobriety Checkpoint

The court held that the checkpoint complied with the Fourth Amendment. Applying the Supreme Court's decision in Michigan Department of State Police v. Sitz, the court considered the government's interest in preventing drunk driving, the intrusion on motorists, and the checkpoint's effectiveness.

The court found that the checkpoint was designed to identify drunk drivers, was marked by flashing lights, was visible to approaching motorists, and used a uniform practice of stopping all vehicles except taxis. The court also noted that two other drivers were arrested that night after breath tests indicated excessive alcohol consumption. The court rejected the plaintiffs' arguments that the checkpoint required additional policies, training, documentation, or other characteristics they identified. It stated that the cited precedent did not impose those requirements and that courts should not second-guess reasonable policy choices within constitutional limits. The defendants' motion for summary judgment on the unconstitutional-traffic-stop claim was granted.

Municipal Liability

The court granted summary judgment on the municipal-liability claim. It explained that a municipal-liability claim under Monell requires an underlying constitutional violation. Because the court found no valid constitutional violation by the defendants, it granted summary judgment for the City on that claim.

Disposition

The defendants' motion for summary judgment was granted. The plaintiffs' motion for partial summary judgment was denied. The Clerk was directed to terminate the motions and mark the case closed.