Law School Case Brief
Ford v. City of Rockford - No. 92-3757, 1995 U.S. App. LEXIS 4677 (7th Cir. Mar. 6, 1995)
To succeed on a 42 U.S.C.S. § 1983 claim for malicious prosecution based on a violation of equal protection rights, a plaintiff must show, in addition to the elements of malicious prosecution under state law, that the defendants purposefully discriminated against him based on his membership in a particular class, not just on an individual basis. That is, plaintiff bears the heavy burden of establishing not only that he was treated differently, but also that the defendants acted with discriminatory intent.
Plaintiff Roy E. Ford was arrested after having an altercation with defendant police officers as they attempted to arrest him for refusing to show his driver's license. The police officers were employed by defendant City of Rockford ("City"). Ford was convicted of obstruction of justice and acquitted of all other charges. Ford filed a 42 U.S.C.S. § 1983 action in federal district court against the City, its commissioners, and the officers to recover damages for malicious prosecution based on the alleged violation of his equal protection rights. The trial court granted defendants' motion to dismiss because the statute of limitations had already run, but allowed Ford to amend the complaint. Ford amended the complaint to allege that defendants maliciously prosecuted him because he was black, which he alleged violated his equal protection rights. The trial court granted summary judgment to defendants.
Were defendants properly granted summary judgment?
The appellate court affirmed and concluded that the malicious prosecution claim was barred because there was probable cause to arrest Ford for his failure to produce a valid driver's license upon request. There was also probable cause to arrest Ford for aggravated battery and resisting arrest because he engaged in a physical altercation with the officers. The existence of probable cause to arrest was an absolute bar to a malicious prosecution claim. The court determined that the officers' actions were motivated by their suspicion of Ford's behavior rather than by racial animus.
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