Meekins v. Oberlin

Citations

• 2019 Ohio 2825

Syllabus

Summary judgment Civ.R. 56 false arrest malicious prosecution 42 U.S.C. 1983 probable cause arrest warrant municipal liability policy or custom moving force behind constitutional violation inadequacy of police training, staffing or supervision deliberate indifference. Trial court erred in entering summary judgment in favor of city because genuine issues of material fact existed regarding city's liability on appellant's claims for false arrest and malicious prosecution under 42 U.S.C. 1983 arising out of allegations that appellant was wrongfully arrested and prosecuted after police failed to properly investigate false claims made by his son's mother that appellant had sent threatening text messages and violated a civil protection order. Triable issues of fact existed as to whether police officer recklessly made misleading statements or omitted material information when requesting a warrant for appellant's arrest, whether municipal court judge would have issued the arrest warrant in the absence of the alleged misleading statements or omissions, whether the alleged inadequacy of the city's staffing, policies, training or supervision was obvious and so likely to result in the violation of the constitutional rights of potential defendants that the city could be found to be deliberately indifferent and whether but for the city's alleged policy or custom of inadequate staffing, training or supervision, appellant's constitutional rights would not have been violated.