Santiago v. City of Yonkers

Background

Jeyson Santiago sued the City of Yonkers, Yonkers Police Officers Brian McCormack and Thomas Sabol, and John or Jane Doe 1-10. His claims arose from his arrest shortly after midnight on March 15, 2019, after he drove the wrong way on a one-way road and attempted an illegal U-turn. The case included federal and state claims concerning an unlawful search and seizure, false arrest and false imprisonment, excessive force, assault and battery, malicious prosecution, malicious abuse of process, denial of a fair trial, equal protection, civil-rights conspiracy, failure to intervene, and negligent hiring, training, retention, and supervision.

The parties gave sharply different accounts of the arrest. The officers said they learned that Santiago had an active arrest warrant, told him he was under arrest, and used force after he resisted handcuffing and tried to flee. Santiago said the officers did not tell him about a warrant, immediately twisted his arms, threw him to the ground, and punched and kicked him while he was on the ground. The court also identified conflicting evidence about how the officers supposedly learned about the warrant and whether the warrant actually applied to Santiago. Santiago was treated after his release for a sprained wrist and multiple contusions.

Rulings on Claims That Proceeded

The court denied summary judgment on Santiago’s false-arrest and false-imprisonment claims. The existence of probable cause—a legally sufficient basis for an arrest—depended on disputed facts about what the officers knew about an outstanding warrant and when they knew it. The court also denied summary judgment on the unlawful-search-and-seizure claims because the defendants’ justification depended on whether the arrest was lawful.

The court denied summary judgment on the excessive-force and assault-and-battery claims. The parties disputed whether Santiago resisted or attempted to flee and whether the officers merely used force to restrain him or instead threw him down and repeatedly punched and kicked him. The court declined to resolve those credibility disputes on summary judgment and rejected the argument that Santiago’s injuries were too minor by themselves to support the claims.

The court denied summary judgment on the failure-to-intervene claims. Because Santiago’s excessive-force claim remained viable, he could pursue these claims against McCormack and Sabol in the alternative. The court also denied the defendants’ request for qualified immunity on the excessive-force, false-arrest, and malicious-prosecution claims. The factual disputes prevented the court from deciding at this stage whether the officers acted reasonably or had “arguable probable cause,” meaning that officers of reasonable competence could reasonably have disagreed about whether probable cause existed.

Malicious Prosecution and Fair-Trial Claims

The court denied summary judgment on Santiago’s malicious-prosecution claims against McCormack and the City of Yonkers. McCormack signed the criminal complaint charging Santiago with resisting arrest and obstructing governmental administration, and factual disputes about probable cause also affected whether there was probable cause to prosecute. The court granted summary judgment on these claims as to Sabol because Santiago presented no evidence that Sabol personally participated in initiating the criminal proceeding.

The court denied summary judgment on Santiago’s denial-of-the-right-to-a-fair-trial claims against McCormack and the City. Santiago’s testimony created a factual dispute about whether McCormack fabricated the account in the criminal complaint and sent that information to prosecutors. The court granted summary judgment on these claims as to Sabol because Santiago presented no evidence that Sabol personally transmitted an account of the arrest to prosecutors.

Claims Dismissed

The court granted summary judgment on Santiago’s malicious-abuse-of-process claims because he offered only conclusory allegations, rather than evidence, that the defendants pursued a collateral objective such as obtaining overtime or increasing their arrest counts.

The court granted summary judgment on the equal-protection claims because Santiago presented no evidence of discriminatory intent or race-based disparate treatment. It also granted summary judgment on the civil-rights conspiracy and failure-to-prevent-conspiracy claims because the record contained no evidence of an agreement between the officers or of racial or other class-based discriminatory intent. The related failure-to-prevent-conspiracy claim depended on a valid conspiracy claim and therefore also failed.

The court granted summary judgment on the negligent-hiring, training, retention, and supervision claim against the City of Yonkers. Santiago presented no evidence about the City’s relevant policies or about the City’s knowledge of any alleged tendency by the officers to engage in the conduct at issue.

The court dismissed all claims against John or Jane Doe 1-10 without prejudice because discovery had closed and Santiago had not identified or added those defendants. In its conclusion, the court stated that claims nine, ten, thirteen, fourteen, fifteen, and eighteen were dismissed with prejudice; claims seven, eight, eleven, and twelve were dismissed as to Sabol only and would proceed against the remaining defendants; and claims one, two, three, four, five, six, sixteen, and seventeen would proceed to trial against the defendants specified for those claims.

Disposition

The defendants’ motion for summary judgment was granted in part and denied in part. The court scheduled a status conference for April 20, 2023, and directed counsel to discuss potential trial dates.