Johnson v. Reed

Background

Carl Michael Johnson filed this action without a lawyer. He alleged false arrest, false imprisonment, and violations of his rights under the First, Fourth, Fifth, and Fourteenth Amendments. Defendants Kyle Reed, Alexander Thornton, and the City of Middletown moved for summary judgment under Federal Rule of Civil Procedure 56.

Johnson alleged that Reed and Thornton arrested him on October 10, 2016, while he was on post-release supervision. He stated that he was held in the Orange County Jail for seven months, experienced assaults and health problems there, and was later told that the criminal case had been dismissed with prejudice. He also alleged that police and victims had given false statements and that witnesses did not appear for later proceedings.

The defendants’ evidence described a domestic-dispute call. A woman reported that Johnson had struck her and her six-year-old daughter. Officers transported the individuals to the police station, where the woman provided additional information and signed a domestic-incident report. Medical records and a child-protection report described facial injuries to the woman and child. The criminal charges were dismissed during trial after the reported victims did not appear to testify; the state judge dismissed the charges with prejudice because jeopardy had attached.

Motion and summary-judgment standard

Johnson did not file an opposition to the motion, even after receiving multiple notices and time to respond. The court nevertheless considered the motion under the ordinary summary-judgment standard rather than granting it automatically. Summary judgment is proper when the evidence shows no genuine dispute about a material fact and the moving party is entitled to judgment as a matter of law. The court also stated that it would interpret Johnson’s filings liberally because he was representing himself.

False-arrest and false-imprisonment claims

The court applied New York law to these claims and explained that New York treats false arrest and false imprisonment as the same claim. Probable cause is a complete defense. Probable cause exists when reasonably trustworthy information would lead a reasonably cautious person to believe that an offense was committed by the person arrested.

The court held that Reed and Thornton had probable cause to arrest Johnson. It relied on the woman’s statements, the injuries observed on the woman and child, the domestic-incident report, medical records, the child-protection report, and photographs of the child’s injuries. Because this evidence provided probable cause, the court found no genuine issue for trial on the false-arrest and false-imprisonment claims.

Constitutional claims

Johnson also asserted violations of the First, Fourth, Fifth, and Fourteenth Amendments based on the same events. The court held that these assertions were conclusory and lacked factual support. It ruled that unsupported assertions could not defeat a properly supported summary-judgment motion and found no genuine issue for trial on the constitutional claims.

Disposition

Judge Nelson S. Roman granted the defendants’ motion for summary judgment in its entirety. The court dismissed the action with prejudice, dismissed all of Johnson’s claims, directed the Clerk to enter judgment for the defendants and close the case, and directed that a copy of the Opinion and Order be mailed to Johnson.