Hernandez v. Sheriff of Manatee County, Florida
Eleventh Circuit Clarifies that Failure to Interview a Suspect, Standing Alone, Does Not Defeat Probable Cause for § 1983 Malicious-Prosecution or False-Arrest Claims

1. Introduction

Between August 2019 and May 2020, Nicolas Hernandez (also known as Nicolas Trupia) was arrested four times by deputies of the Manatee County Sheriff’s Office (“MCSO”). Although prosecutors eventually abandoned every charge, Hernandez sued four deputies in their individual capacities under 42 U.S.C. § 1983, asserting two malicious-prosecution claims and two false-arrest claims predicated on the Fourth Amendment’s prohibition against unreasonable seizures. The district court dismissed all claims on qualified-immunity grounds. On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed, holding that Hernandez failed to plausibly plead a Fourth-Amendment violation. Crucially, the court ruled that:

• Merely omitting an interview of the suspect does not render a warrant affidavit constitutionally deficient.
• An officer executing a facially valid warrant cannot ordinarily incur § 1983 false-arrest liability, irrespective of the underlying facts subsequently proving inadequate.
• Under the “any-crime rule,” probable cause for one offense defeats a false-arrest claim even where the stated arrest offense lacks probable cause.

These clarifications collectively set a practical pleading bar for § 1983 plaintiffs in the Eleventh Circuit who challenge arrests that rest on warrants or on victim/witness statements later recanted.

2. Summary of the Judgment

The Eleventh Circuit, per curiam (Judges Luck, Lagoa, and Abudu), affirmed dismissal of all four § 1983 claims. The court held:

1. Malicious Prosecution – August 2019 arrest (Deputy Girgis): Hernandez failed to allege that Girgis knowingly or recklessly included misstatements or omitted material facts in the theft-warrant affidavit, or that he should have known the affidavit lacked probable cause.
2. Malicious Prosecution – January 2020 arrest (Deputy Santana): Hernandez’s allegation that Santana “should have known” probable cause was absent was conclusory; without plausible factual support, the claim failed at the Iqbal/Twombly pleading stage.
3. False Arrest – April 2020 arrest (Deputy Riley): Riley executed a facially valid warrant for driving with a suspended license; therefore probable cause existed as a matter of law, and the “any-crime rule” insulated the arrest even assuming no probable cause for the accompanying resisting-arrest charge.
4. False Arrest – May 2020 warrantless arrest (Deputy Cowling): Victim statements supplied probable cause to arrest for battery. Later recantations and the deputy’s failure to interview Hernandez did not vitiate probable cause assessed at the moment of arrest.

3. Detailed Analysis

3.1 Precedents Cited and Their Influence

• Thompson v. Clark, 596 U.S. 36 (2022) – Provided the modern Supreme Court framework for malicious-prosecution claims as Fourth-Amendment unreasonable-seizure cases.
• Williams v. Aguirre, 965 F.3d 1147 (11th Cir. 2020) – Distinguished between malicious-prosecution and false-arrest theories; reinforced that executing a facially valid warrant usually shields an officer from false-arrest liability.
• District of Columbia v. Wesby, 583 U.S. 48 (2018) – Emphasized that officers need not rule out every innocent explanation and that probable cause is a practical, non-technical concept; the panel relied heavily on this principle to reject arguments based on the deputies’ failure to interview Hernandez.
• Harris v. Hixon, 102 F.4th 1120 (11th Cir. 2024) – Reiterated that the Fourth Amendment does not demand a perfect investigation before an arrest; cited to disregard Hernandez’s “insufficient investigation” theory.
• Sylvester v. Fulton County, 94 F.4th 1324 (11th Cir. 2024) – Demonstrated when intentional or reckless omissions can vitiate probable cause, but the court distinguished Sylvester because Hernandez pled no intentional or reckless deceit.
• Black v. Wigington, 811 F.3d 1259 (11th Cir. 2016) and Laskar v. Hurd, 972 F.3d 1278 (11th Cir. 2020) – Supplied the malicious-prosecution elements and clarified the need to allege malice plus absence of probable cause.
• Garcia v. Casey, 75 F.4th 1176 (11th Cir. 2023) and Bailey v. Board of County Commissioners, 956 F.2d 1112 (11th Cir. 1992) – Anchored the “any-crime rule.”
• Ashcroft v. Iqbal, 556 U.S. 662 (2009) – Grounded the court’s two-step pleading review, leading to exclusion of Hernandez’s conclusory assertions.

3.2 The Court’s Legal Reasoning

3.2.1 Malicious Prosecution Framework

To satisfy a Fourth-Amendment malicious-prosecution claim the plaintiff must allege (i) the common-law elements (institution of prosecution, malice, lack of probable cause, favorable termination, damages) and (ii) a Fourth-Amendment seizure. The court focused on the absence of probable cause prong.

• No intentional or reckless falsehoods: Hernandez alleged none, thereby failing the Sylvester-type scenario.
• No conscious investigative defect: Citing Washington v. Rivera, the court held that not interviewing Hernandez, without more, did not show a deliberate avoidance of exculpatory evidence.
• Conclusory pleadings rejected: The assertion that Santana “should have known” probable cause was lacking was treated as an impermissible legal conclusion.

3.2.2 False Arrest Analysis

For a false-arrest claim the plaintiff must plead absence of probable cause. Two distinct situations arose:

1. Arrest pursuant to a warrant (Deputy Riley): Under Williams, a facially valid warrant extinguishes false-arrest liability. Riley’s warrant was facially valid because a deputy—not Riley—had supplied an affidavit meeting probable-cause standards. Abandonment of the charge months later had no retroactive effect on probable cause.
2. Warrantless arrest (Deputy Cowling): The alleged victims’ on-scene statements provided probable cause for battery. Later recantation and deputy’s failure to interview Hernandez were irrelevant to the assessment of probable cause at the time of arrest.

3.2.3 The “Any-Crime Rule”

Even if probable cause for the stated offense is questionable, arrest is lawful if probable cause existed for any offense. Here, probable cause for driving with a suspended license insulated Riley from liability despite the supposed lack of probable cause for resisting arrest; likewise, battery probable cause insulated Cowling despite doubts about burglary.

3.3 Practical & Doctrinal Impact

• Pleading Threshold Raised: Plaintiffs must now allege concrete facts showing deliberate or reckless misstatements/omissions or conscious investigative avoidance to survive dismissal when a warrant is involved.
• Reinforcement of Wesby/Harris Line: The court aligns with Supreme Court and Eleventh-Circuit precedent emphasizing pragmatic probable-cause determinations and rejecting a “perfect investigation” expectation.
• Clarification on Charge Dismissals: Prosecutorial abandonment of charges— common in busy state dockets— does not retroactively negate probable cause or establish innocence for § 1983 purposes.
• Expansion of Any-Crime Rule Application: The decision reaffirms that plaintiffs challenging multi-charged arrests must negate probable cause for every plausible offense at the pleading stage.
• Qualified-Immunity Strategy: While the panel technically decided the case on the antecedent question (no constitutional violation), the analysis signals that plaintiffs who cannot surmount the constitutional-violation hurdle will rarely proceed to the “clearly established” prong.

4. Simplifying Key Legal Concepts

Probable Cause

A reasonable ground to believe that a person has committed, is committing, or is about to commit a crime. It is a common-sense, flexible standard—not proof beyond a reasonable doubt.

Malicious Prosecution (Fourth Amendment)

When an officer initiates or continues a prosecution through legal process (e.g., warrant affidavit) without probable cause and with malice, causing an unreasonable seizure.

False Arrest

An arrest made without probable cause and without a valid warrant.

Facially Valid Warrant

A warrant that, on its face, is properly issued by a neutral magistrate and supported by an affidavit stating probable cause. Executing officers may generally rely on it.

Any-Crime Rule

If probable cause exists for any criminal offense, an arrest is constitutionally valid even if the officer cites or intends a different offense.

Investigative Defect

An officer’s deliberate or reckless decision to ignore readily available exculpatory evidence. Such a defect can undermine probable cause.

5. Conclusion

Hernandez v. Sheriff of Manatee County crystallizes several vital points for civil-rights practitioners in the Eleventh Circuit:

1. Omitting an interview of the suspect, without specific allegations of deliberate avoidance of exculpatory evidence, does not strip a warrant affidavit of probable cause.
2. Executing a facially valid warrant normally forecloses a § 1983 false-arrest claim, and subsequent dismissal of charges is irrelevant.
3. The “any-crime rule” remains robust: plaintiffs must negate probable cause for all plausible offenses, not just the booked charge.
4. Conclusory assertions that deputies “should have known” probable cause was lacking cannot survive the Iqbal/Twombly plausibility filter.

Practically, the decision heightens the factual specificity plaintiffs must plead and underscores deference to officers’ on-the-spot assessments. Unless a plaintiff can point to deliberate falsifications, reckless omissions, or a total absence of objective facts supporting any crime, § 1983 malicious-prosecution and false-arrest claims in the Eleventh Circuit will face an uphill battle.