Mitchell v. City of Jackson
Mitchell v. City of Jackson
Opinion
Appellants brought a 42 U.S.C. § 1983 claim below, alleging their Fourth and Fifth Amendment rights were violated because they were arrested and detained without probable cause. Plaintiffs also raised pendant state law claims. Appellees moved for summary judgment arguing, inter alia, that the undisputed facts established probable cause and that the suit was barred by qualified immunity. The district court granted Defendants’ motion, finding the arrest and detention supported by probable cause and holding that, in the alternative, Appellants’ claims were barred by qualified immunity. 1
Based on our de novo review, we agree with the district court that the undisputed *412 facts establish that probable cause existed as a matter of law. Probable cause exists when the facts and circumstances as known to the officers at the time would “warrant a prudent man [to] believe[ ] that the [Appellants] had committed or [were] committing an offense.” Martin v. Thomas, 973 F.2d 449, 453 (5th Cir. 1992). It is irrelevant that the Appellants were not ultimately convicted. See Morris v. Dillard Dep’t Stores, Inc., 277 F.3d 743, 754 (5th Cir. 2001).
Because we find Appellants’ arrest supported by probable cause, we need not decide whether Appellees are entitled to qualified immunity. We affirm.
AFFIRMED.
Case-law data current through December 31, 2025. Source: CourtListener bulk data.