Introduction

In Jeff Fleuranville v. Miami Dade County, No. 24-11741 (11th Cir. Apr. 4, 2025) (per curiam) (unpublished), the Eleventh Circuit affirmed the dismissal of a civil-rights suit arising from the arrest and prosecution of a son accused of sexually assaulting his elderly mother. The key issues were whether the officers had probable cause to arrest based primarily on the victim’s statements and whether that probable cause defeated federal and state claims for false arrest and malicious prosecution. The court held that the officers were entitled to qualified immunity on the federal claims and that probable cause barred the parallel Florida tort claims.

The decision underscores a recurring principle in Fourth Amendment jurisprudence: officers may rely on a victim’s detailed criminal complaint to establish probable cause unless they are aware of circumstances that would render the complaint unreliable. The court further clarified that subsequent decisions by prosecutors to “no action” or nolle prosequi charges do not retroactively vitiate probable cause or resuscitate false-arrest or malicious-prosecution claims.

Summary of the Opinion

The panel (Judges Rosenbaum, Abudu, and Black) affirmed the Southern District of Florida’s order dismissing the amended complaint. The court concluded:

• There was probable cause to arrest based on the elderly victim’s detailed account identifying her son as the perpetrator of sexual assaults and related offenses. The victim also disclosed the assaults to her daughter.
• Because probable cause existed, the federal false arrest claim failed and the officers were entitled to qualified immunity.
• Under Florida law, probable cause likewise bars false arrest claims, warranting dismissal of the state claims.
• For malicious prosecution (federal and state), the absence of probable cause is an element. The presence of probable cause foreclosed those claims as well, notwithstanding the later entry of a nolle prosequi.
• The panel did not reach the alternative argument that the complaint failed to meet pleading standards because the district court did not dismiss on that ground.

Factual and Procedural Background

On May 11, 2018, a 74-year-old woman reported to police that her son, Jeff Fleuranville, had sexually assaulted her on multiple occasions. An arrest affidavit summarized a detailed description of an incident in November 2017, including forced intercourse, physical assaults (slapping and kicking), a threat to kill her if she reported the crimes, and her resulting fear and inability to leave the home for several days. The victim disclosed the assaults to her daughter as well.

Officers arrested Fleuranville on multiple felony counts, including sexual battery, kidnapping, and battery on the elderly. Within weeks, sexual battery charges were “no actioned,” and charges were amended to one kidnapping and one battery count. Ultimately, on July 25, 2019, the State entered a nolle prosequi and closed the case.

Fleuranville then filed a civil rights action asserting:

• Federal false arrest claims under 42 U.S.C. § 1983 against several Miami-Dade County Police Department officers;
• Federal malicious prosecution claims under § 1983 against those officers;
• Parallel Florida false arrest and malicious prosecution claims.

He alleged, among other things, that his mother suffered from dementia and other mental health conditions, that he had never abused her, and that law enforcement knew her prior reports had been unfounded. He also alleged the investigation lacked corroboration (no rape kit, medical records, APS investigation, etc.). The district court granted the motion to dismiss, finding probable cause and, therefore, qualified immunity on the federal claims and preclusion of the Florida tort claims.

Detailed Analysis

1) Precedents Cited and Their Influence

• Davis v. Carter, 555 F.3d 979 (11th Cir. 2009): The court reaffirmed de novo review of a qualified immunity dismissal at the Rule 12 stage, accepting factual allegations as true and drawing reasonable inferences in the plaintiff’s favor.
• Dukes v. Deaton, 852 F.3d 1035 (11th Cir. 2017): Establishes that officers first must show they acted within discretionary authority. This was undisputed here. Once shown, the burden shifts to the plaintiff to demonstrate a constitutional violation of clearly established law.
• Barnes v. Zaccari, 669 F.3d 1295 (11th Cir. 2012): Confirms the two-pronged plaintiff’s burden in qualified immunity analysis: (1) violation of a constitutional right; and (2) clearly established law at the time.
• Richmond v. Badia, 47 F.4th 1172 (11th Cir. 2022): Provides the elements of a false arrest claim under § 1983: lack of probable cause and an arrest. If probable cause exists, the claim fails.
• Washington v. Howard, 25 F.4th 891 (11th Cir. 2022), quoting District of Columbia v. Wesby, 583 U.S. 48 (2018): Articulates the modern, practical probable-cause standard: under the totality of the circumstances, a reasonable officer must have a “probability or substantial chance” of criminal activity. Probable cause is not a high bar and does not require conclusive evidence.
• Rankin v. Evans, 133 F.3d 1425 (11th Cir. 1998): Critical to this case. It holds that officers may generally rely on a victim’s complaint to establish probable cause, even when the victim is a child whose statements must be evaluated in light of her age and potential inconsistencies. The court found the child’s statements sufficiently reliable when viewed with supporting evidence. This authority directly supports relying on the mother’s account here.
• Crocker v. Beatty, 995 F.3d 1232 (11th Cir. 2021): Confirms that probable cause bars false arrest claims under Florida law just as it does under federal law.
• Laskar v. Hurd, 972 F.3d 1278 (11th Cir. 2020): Sets out the federal malicious prosecution elements in the Eleventh Circuit: the common-law elements plus a seizure pursuant to legal process that violates the Fourth Amendment.
• Durkin v. Davis, 814 So. 2d 1246 (Fla. 2d DCA 2002): Under Florida law, malicious prosecution requires the absence of probable cause, among other elements. Presence of probable cause is fatal to the claim.

Collectively, these authorities shape the opinion’s core holding: a detailed victim complaint—without known indicators of unreliability—can suffice for probable cause; the existence of probable cause defeats false arrest and malicious prosecution claims under both § 1983 and Florida law; and qualified immunity applies where no Fourth Amendment violation is shown.

2) The Court’s Legal Reasoning

The court proceeded through the familiar qualified immunity framework. Because the officers were indisputably acting within their discretionary authority, the burden shifted to Fleuranville to show a constitutional violation of clearly established law. His claims turned on whether there was a lack of probable cause for his arrest (false arrest) and for initiating or continuing a prosecution (malicious prosecution).

Applying Washington v. Howard and Wesby, the court asked whether, under the totality of the circumstances known to a reasonable officer at the time, there was a substantial chance of criminal activity. The opinion highlighted the following:

• The victim’s detailed statements in the arrest affidavit accused her son of forced intercourse, physical assault, threats to kill her if she told anyone, and her resulting fear and confinement.
• The victim disclosed the assaults to her daughter, adding a degree of corroboration.
• Even though the plaintiff claimed his mother had dementia and a history of unfounded complaints, the amended complaint did not allege that the particular arresting officers were aware of those facts when they made the arrest.

Anchored by Rankin v. Evans, the court reiterated that officers may ordinarily rely on a victim’s criminal complaint to establish probable cause. While some circumstances may call for additional scrutiny (e.g., known inconsistencies or known unreliability), no such officer knowledge was adequately alleged here. The officers were therefore permitted to credit the complainant’s detailed report.

The court rejected the contention that officers were required to conduct a more exhaustive investigation—such as obtaining a rape kit, medical records, an APS investigation, eyewitnesses, audio or video recordings, polygraphs, or a confession—before arresting. Probable cause does not demand conclusive proof or the elimination of all innocent explanations; it requires only a fair probability under the totality of the circumstances. The victim’s account met that threshold.

Because probable cause existed:

• Federal false arrest claims failed on the merits, and qualified immunity applied.
• Florida false arrest claims were likewise barred because Florida law mirrors federal law on this point.
• Federal and Florida malicious prosecution claims were foreclosed, as absence of probable cause is an essential element under both federal and Florida frameworks (Laskar; Durkin). The later entry of nolle prosequi is a favorable termination but does not cure the presence of probable cause.

Finally, the panel noted that although the officers argued the amended complaint failed to meet pleading standards, the district court did not dismiss on that ground, so the Eleventh Circuit did not address it on appeal.

3) Doctrinal Clarifications and Context

• Probable cause vs. “arguable probable cause”: In qualified immunity cases, officers are often entitled to immunity if “arguable probable cause” existed—i.e., reasonable officers in the same circumstances could disagree on the existence of probable cause. This opinion went further and found actual probable cause, making it unnecessary to address the arguable probable cause standard.
• Reliance on victim statements: Rankin remains a bedrock Eleventh Circuit rule: an officer may rely on a victim’s complaint unless the officer is aware of facts that render it untrustworthy. Age, impairment, or inconsistency can affect reliability, but the key is what the officer knew at the time. Here, no well-pled facts showed the officers were aware of the alleged dementia or history of unfounded reports.
• Effect of dropped charges: A prosecutor’s decision to “no action” or later nolle prosequi may satisfy favorable termination for malicious prosecution but does not retroactively eliminate probable cause at the relevant time. Thus, dismissal of criminal charges does not by itself establish a lack of probable cause or a constitutional violation.
• Scope of investigation: The Fourth Amendment does not oblige officers to execute every conceivable investigative step before making an arrest supported by probable cause. The opinion’s rejection of demands for further forensic or corroborative evidence tracks the Supreme Court’s and Eleventh Circuit’s emphasis on practicality and the totality standard in Wesby and Washington.
• Unpublished, non-argument decision: The opinion is designated “Do Not Publish” and decided on the non-argument calendar. It is not binding precedent but is persuasive and consistent with published Eleventh Circuit and Supreme Court authority.
• Parties and pleadings nuance: Although the appellate caption lists Miami Dade County, the opinion notes the County was not named as a defendant in the amended complaint. The appeal therefore focused on claims against individual officers; no municipal liability analysis was at issue.

4) Impact and Practical Implications

This opinion reinforces several practical points for future cases:

• Law enforcement: Officers may rely on a detailed victim complaint to establish probable cause without first obtaining corroborating forensic or testimonial evidence, especially where there are no known red flags about the complainant’s reliability. This is particularly significant in sensitive offenses like sexual assault, where immediate forensic corroboration may be absent.
• Civil rights litigants: To overcome qualified immunity on a false arrest claim in the Eleventh Circuit, plaintiffs generally must plead facts showing the absence of probable cause in light of what the arresting officers actually knew, including any known reasons to doubt the veracity or reliability of the victim. Allegations about the victim’s impairments or prior unfounded complaints, without alleging officer awareness, will rarely suffice.
• Malicious prosecution strategy: While a later dismissal or nolle prosequi may meet the favorable termination element, plaintiffs must still plausibly allege that the prosecution was initiated without probable cause. When the arrest itself is supported by probable cause, malicious prosecution claims often fail absent new material facts (e.g., fabrication of evidence) arising during the prosecution.
• Florida tort claims alignment: The opinion highlights the close alignment between federal and Florida doctrines on false arrest and malicious prosecution regarding the centrality of probable cause. A finding of probable cause typically forecloses both sets of claims.

Complex Concepts Simplified

• Probable cause: A practical, common-sense standard. It exists when, under all the circumstances known to the officers, there is a fair probability that a crime has been committed. It does not require proof beyond a reasonable doubt or conclusive evidence.
• Qualified immunity: Shields government officials from civil liability unless they violate a constitutional right that was clearly established at the time. In false arrest cases, if probable cause existed, there is no constitutional violation; if arguable probable cause existed, qualified immunity typically applies.
• False arrest (federal and Florida): Requires an arrest and lack of probable cause. If probable cause exists, the claim fails.
• Malicious prosecution (federal and Florida): Requires, among other elements, that the criminal process was instituted without probable cause and terminated in the plaintiff’s favor. A nolle prosequi may be a favorable termination, but the claim still fails if probable cause was present.
• “No actioned” and “nolle prosequi”: “No actioned” typically means prosecutors chose not to file or proceed with certain charges at that time. “Nolle prosequi” is a formal notice by the prosecution that it will not pursue the pending charges. Neither event, by itself, proves the absence of probable cause at the time of arrest or initiation of prosecution.
• Discretionary authority: Actions undertaken by officers in performing their official duties. Once shown, the plaintiff must demonstrate a constitutional violation of clearly established law to overcome qualified immunity.
• Non-argument calendar; per curiam; unpublished: The court decided the case without oral argument; the opinion is issued in the court’s name rather than a single judge’s; and “Do Not Publish” signals it is nonprecedential but may be persuasive.

Conclusion

The Eleventh Circuit’s unpublished decision in Fleuranville reaffirms a central Fourth Amendment rule: officers may generally rely on a victim’s detailed report to establish probable cause absent known reasons to doubt reliability. That probable cause defeats false arrest claims and forecloses malicious prosecution claims under both § 1983 and Florida law. The court’s reasoning tracks Supreme Court and Eleventh Circuit precedent emphasizing the practical, totality-of-the-circumstances standard for probable cause and the protective scope of qualified immunity.

For investigators, the case confirms that immediate arrest decisions can be lawful based on a credible victim complaint, even when subsequent forensic corroboration is limited or absent. For plaintiffs, it highlights the importance of pleading officer knowledge of facts undermining the complainant’s reliability to survive a motion to dismiss. More broadly, the opinion illustrates how probable cause at the outset can determine the fate of both federal and state civil claims that follow, notwithstanding the eventual termination of criminal proceedings in the accused’s favor.