Qualified Immunity for Officers Exercising Stop-and-Identify Authority: Arguable Reasonable Suspicion and Probable Cause in Metz v. Bridges

Introduction

In George D. Metz, II v. D. Bridges, No. 23-11275 (11th Cir. Dec. 12, 2024), the Eleventh Circuit addressed the scope of qualified immunity in a § 1983 claim arising from an encounter in a state welfare office. Plaintiff George Metz and an associate entered the Houston County Department of Human Resources (DHR) to film a news segment. A security guard ordered them to leave based on a no-filming policy; they refused. Police officers Bridges and Dodson arrived, asked for identification, handcuffed the men when they refused, and searched them incident to arrest for trespass. Metz sued under 42 U.S.C. § 1983, alleging Fourth Amendment unlawful search and seizure. The district court denied qualified immunity; on appeal, the Eleventh Circuit reversed.

Summary of the Judgment

The Eleventh Circuit held that Officers Bridges and Dodson were entitled to qualified immunity because they had “arguable reasonable suspicion” to effect a Terry stop for trespass and “arguable probable cause” to arrest Metz when he refused to identify himself under Alabama’s stop-and-identify statute. The Court emphasized that:

Undisputed video evidence supported a finding that Metz was knowingly filming in a building he was ordered to vacate, satisfying the elements of criminal trespass under Ala. Code § 13A-7-4(a).
Alabama’s stop-and-identify statute (Ala. Code § 15-5-30) permitted an officer who reasonably suspected a public offense to demand a suspect’s name and address; refusal to comply provided at least arguable probable cause for arrest.
Once Metz was in handcuffs, Officer Dodson’s subsequent search was a lawful search incident to arrest under United States v. Robinson, 414 U.S. 218 (1973).

Accordingly, the Court reversed the district court’s denial of qualified immunity and dismissed the appeal.

Analysis

Precedents Cited

Hope v. Pelzer, 536 U.S. 730 (2002) – Defines the “clearly established law” prong of qualified immunity.
Baker v. City of Madison, 67 F.4th 1268 (11th Cir. 2023) – Permits consideration of body-worn camera footage at the motion-to-dismiss stage.
Horsley v. Feldt, 304 F.3d 1125 (11th Cir. 2002) – Clarifies when documentary evidence may supplement pleadings.
Chesser v. Sparks, 248 F.3d 1117 (11th Cir. 2001) – Establishes de novo review for qualified immunity denials on motions to dismiss.
Jordan v. Mosley, 487 F.3d 1350 (11th Cir. 2007) – Defines “arguable reasonable suspicion” for Terry stops.
Hiibel v. Sixth Judicial District Court of Nevada, 542 U.S. 177 (2004) – Upholds state stop-and-identify statutes and confirms refusal to identify can support probable cause.
Illinois v. Wardlow, 528 U.S. 119 (2000) – Discusses reasonable suspicion under the Fourth Amendment.
United States v. Robinson, 414 U.S. 218 (1973) – Authorizes searches incident to a lawful arrest.
District of Columbia v. Wesby, 583 U.S. 48 (2018) – Explains probable cause as a “substantial chance of criminal activity.”
Paez v. Mulvey, 915 F.3d 1276 (11th Cir. 2019) – Confirms probable cause does not require conclusive proof or preponderance of evidence.

These cases collectively guided the Court in determining that officers were entitled to immunity when they acted on information that, while disputed by the plaintiff, was “arguably” sufficient to satisfy Fourth Amendment thresholds.

Legal Reasoning

The Court’s reasoning unfolded in three main steps:

Arguable Reasonable Suspicion for Trespass: Officers Bridges and Dodson responded to a 911 call from a DHR employee who reported two men “filming inside a building they’re not supposed to be in.” Upon arrival, DHR staff pointed out Metz and his associate actively recording in the lobby. Under Alabama law, criminal trespass occurs when a person “knowingly enters or remains unlawfully” on premises (Ala. Code § 13A-7-4(a)). Given this backdrop, a reasonable officer could believe Metz was trespassing, justifying a brief investigatory stop (Terry v. Ohio).
Stop-and-Identify Demand and Arguable Probable Cause: During the Terry stop, Officer Bridges invoked Alabama’s stop-and-identify statute (Ala. Code § 15-5-30), which permits an officer who “reasonably suspects” a public offense to demand a suspect’s name and address. Metz’s repeated refusals to comply provided “arguable probable cause” to arrest him under Hiibel, which held that refusal to identify under a valid stop-and-identify statute can support probable cause.
Search Incident to Arrest: Once handcuffed, Metz’s status shifted from a detainee to an arrestee. Under United States v. Robinson, officers may conduct a warrantless search of the person incident to a lawful custodial arrest to protect officer safety and preserve evidence. Officer Dodson’s search therefore fell within this well-established exception.

Because each step—stop, identify demand, arrest, search—had “arguable” constitutional validity, the officers were shielded by qualified immunity.

Impact

The decision in Metz v. Bridges will influence future § 1983 litigation and law enforcement practices in several ways:

Lowered Threshold for “Arguable” Cause: Reaffirms that officers need not have textbook probable cause or reasonable suspicion; a reasonable but mistaken conclusion suffices for immunity.
Application of Stop-and-Identify Statutes: Clarifies that refusal to identify under state statutes can serve as the basis for a lawful arrest, even in locations open to the public but subject to no-trespass policies.
Use of Video Evidence at the Pleading Stage: Endorses considering unchallenged body-worn camera or bystander footage when adjudicating qualified immunity on a motion to dismiss.
Guidance for Law Enforcement Training: Emphasizes the importance of documenting third-party complaints, articulating specific grounds for suspicion, and following statutory procedures when demanding identification.

Complex Concepts Simplified

Qualified Immunity: Shields government officials from civil liability unless they violate a “clearly established” constitutional right that a reasonable person would know.
Arguable Reasonable Suspicion: A lower standard than actual reasonable suspicion; officer’s reasonable but mistaken belief suffices to justify a Terry stop.
Arguable Probable Cause: A lower threshold than actual probable cause; if an officer could reasonably believe there was a substantial chance of criminal activity, immunity attaches.
Terry Stop: A brief investigatory detention based on reasonable suspicion of criminal activity (Terry v. Ohio).
Stop-and-Identify Statute: A law permitting officers to demand a suspect’s identity when they reasonably suspect a public offense, with refusal providing grounds for arrest.
Search Incident to Arrest: A recognized exception to the Fourth Amendment’s warrant requirement, allowing a cursory search of an arrestee for weapons or evidence.

Conclusion

Metz v. Bridges establishes that officers who act on reasonably trustworthy information—including third-party complaints and unchallenged video—are protected by qualified immunity when they make stops, demand identification, and arrest based on state stop-and-identify and trespass statutes. The Eleventh Circuit’s emphasis on “arguable” suspicion and probable cause reinforces a pragmatic balance: officers need not be infallible, but they must have an objectively reasonable basis for their decisions. This ruling will guide law enforcement protocols and shape the contours of Fourth Amendment litigation in the Circuit going forward.