Background
Christopher Lockhart, a bail bondsman, was stopped by Siloam Springs police officer Zachary Ware for driving below the speed limit and crossing the centerline. During the stop, Ware observed Lockhart’s slurred speech, bloodshot eyes, and poor performance on field sobriety tests. Lockhart disclosed he had taken prescription medication and had a hip replacement. Despite a zero blood alcohol result and a Drug Recognition Expert’s opinion that Lockhart was not impaired due to medical issues, Ware arrested Lockhart for driving while intoxicated. Lockhart was later found not guilty of the DWI charge. He sued Ware and the city under Section nineteen eighty-three, alleging false arrest and malicious prosecution. The district court denied summary judgment for Ware on the false arrest claim, finding a genuine issue of material fact regarding probable cause.
The court’s reasoning
The Eighth Circuit determined that the district court erred in denying qualified immunity to Officer Ware. The court clarified that the inquiry is whether the officer had probable cause to believe the plaintiff committed a crime, not whether a jury might find the plaintiff innocent. The court found that Ware’s observations of Lockhart’s physical symptoms and behavior, combined with Lockhart’s admission of taking prescription medication, provided a substantial chance of criminal activity. The court held that the zero blood alcohol result did not eliminate probable cause for drug impairment and that the officer was not required to disregard his own observations in favor of a conflicting expert opinion. The court also declined to review the city’s appeal on the malicious prosecution claim, noting that this issue was already resolved in a prior decision in this case.
What it means going forward
Police officers are protected by qualified immunity when they arrest individuals based on observable signs of impairment, even if those signs could be explained by medical conditions, provided the totality of circumstances suggests a substantial chance of criminal activity.