Medina v. The City of New York

Background

Zahirah Medina alleged that New York Police Department officers arrested her after discovering that the vehicle identification number on her registration did not match the number on her vehicle. She had purchased the vehicle from Gordon’s Auto Sales, LLC, which had given her temporary Georgia license plates. Medina said she was surprised by the mismatch and was trying to contact the dealership when an officer told her to end the call and exit the car.

Medina was arrested and charged with four counts of criminal possession of a forged instrument in the third degree. She appeared in court four times. At the final appearance, she produced a notarized statement from the dealership saying that the incorrect vehicle identification number on the registration resulted from a dealership error. The charges were ultimately dismissed. Medina alleged that the arrest caused her to be suspended from employment at Newark Airport and caused her to fail a prospective employer’s background check.

Medina asserted federal claims under 42 U.S.C. § 1983 against the City of New York and Officer Christopher Wintermute for false arrest, malicious prosecution, denial of a fair trial, and denial of due process. She also asserted state-law claims for intentional infliction of emotional distress, negligence, negligent hiring, training, and supervision, and violations of the New York State Constitution. Gordon’s Auto Sales, LLC was also named as a defendant, but the court had previously entered default judgment against it. The defendants addressed in this opinion were the City and Officer Wintermute.

Motion and legal standard

The City and Officer Wintermute moved for judgment on the pleadings under Federal Rule of Civil Procedure 12(c). The court applied the same standard used for a motion to dismiss for failure to state a claim: the complaint had to contain enough factual matter, accepted as true, to state a plausible claim for relief. The court relied only on the complaint and did not consider sworn testimony attached to the defendants’ answer.

False arrest

The court held that Officer Wintermute had probable cause to arrest Medina for possessing a forged instrument in the third degree. Probable cause means facts or reasonably trustworthy information that would cause a reasonably cautious person to believe an offense had been committed. The court reasoned that the mismatched vehicle identification numbers made it reasonable for the officer to believe that Medina possessed a forged registration.

The court rejected Medina’s argument that the officer lacked probable cause because he had no evidence that she knew the registration was forged. Probable cause to arrest does not require evidence of every fact that prosecutors would later need to prove at trial, including a person’s knowledge or intent. The officer also was not required to accept Medina’s explanation at face value or investigate every possible innocent explanation.

Because probable cause is a complete defense to a false-arrest claim, the court concluded that Medina’s false-arrest claim could not stand. The court did not decide whether the officer also had probable cause to arrest her for other offenses because the complaint alleged that she was charged with possession of a forged instrument in the third degree.

Malicious prosecution

The court held that the probable cause supporting Medina’s arrest also defeated her malicious-prosecution claim. A malicious-prosecution claim requires, among other things, a lack of probable cause to begin the criminal proceeding. A claim may survive an established finding of probable cause only if facts discovered between the arrest and the start of prosecution undermined that probable cause.

The court found that Medina had not alleged such an intervening fact. She did not produce the dealership’s notarized statement until nearly three months after her arrest and after the prosecution had begun. The court therefore concluded that the malicious-prosecution claim failed.

Denial of a fair trial

To state a fair-trial claim, Medina had to allege that Officer Wintermute intentionally fabricated information likely to influence a jury, forwarded that information to prosecutors, and caused her to lose her liberty as a result. The court found that her allegation that the officer made false statements was conclusory and unsupported.

The complaint acknowledged that the vehicle identification number on the registration did not match the number on the vehicle. The court said Medina alleged no facts suggesting that the officer reported anything beyond that undisputed mismatch. Her argument that the officer should have investigated an innocent explanation did not show intentional fabrication. The court therefore held that she failed to state a fair-trial claim.

Due process

Medina alleged that her federal due-process rights were violated when she was denied a telephone call at the precinct after her arrest. She relied on New York Criminal Procedure Law § 140.20(7), which generally requires police to allow an arrested person, upon request, to make a telephone call for purposes including obtaining counsel or informing a relative or friend, subject to stated exceptions.

The court held that this state procedural rule did not create a liberty interest protected by the federal Constitution. It therefore dismissed Medina’s due-process claim based on the alleged denial of a telephone call.

State-law claims and disposition

After disposing of all of Medina’s federal claims, the court declined to exercise supplemental jurisdiction over her remaining state-law claims. Supplemental jurisdiction is the court’s authority to hear related state-law claims alongside federal claims; the court explained that this authority is discretionary after all claims supporting federal jurisdiction have been dismissed.

The court granted the defendants’ motion for judgment on the pleadings. It directed the Clerk of Court to close the motion at docket entry 30. The court also ordered Medina to move for an inquest by May 21, 2021, to determine the damages owed by Gordon’s Auto Sales, LLC under the previously entered default judgment.