Background
Christopher Majors sued Detective Jason Hatcher and the City of West Des Moines under Section nineteen eighty-three of Title forty-two of the United States Code, alleging his arrest was illegal because the warrant affidavit contained false statements. The district court granted summary judgment for the defendants, and Majors appealed.
The court’s reasoning
The court reviewed the case de novo and found that a valid arrest warrant is fatal to claims of unlawful seizure. Majors argued the affidavit violated Franks versus Delaware by including false statements about a fractured rib and the review of medical records. The court determined that even excluding those statements, the affidavit still established probable cause based on witness accounts of a physical struggle and corroborating injuries to the victim’s ribs. Consequently, the court found no Franks violation and affirmed the summary judgment.
A valid arrest warrant is fatal to all of Majors’s claims against Detective Hatcher.
Majors v. City of West Des Moines, 24-3189 (8th Cir. 2026)
What it means going forward
The ruling reinforces that officers are protected from liability for arrests made under a valid warrant, even if the underlying affidavit contains minor inaccuracies that do not negate probable cause.