Background
Amberley Lambert sued Officer Tammie Heeth and the City of Onalaska under Section nineteen eighty-three of Title forty-two of the United States Code. The dispute arose from an incident at an elementary school where Lambert drove against traffic directions given by Officer Heeth. Officer Heeth attempted to stop Lambert, leading to a physical confrontation and Lambert’s arrest for aggravated assault and resisting arrest. Lambert alleged violations of her First and Fourth Amendment rights, claiming the arrest was retaliatory and unlawful.
The court’s reasoning
The court analyzed the Fourth Amendment claim first, determining that Officer Heeth had probable cause to stop and arrest Lambert. The officer observed Lambert driving against a lawful order after three other drivers had complied. The court found that Lambert’s resistance to being pulled from her vehicle provided additional probable cause for resisting arrest. Regarding the First Amendment claim, the court applied the framework from Nieves versus Bartlett. Because probable cause existed, Lambert needed to prove she was arrested when similarly situated individuals who did not engage in protected speech were not. The court found Lambert failed to provide objective evidence of such comparators, as her conduct was not endemic like jaywalking.
What it means going forward
The ruling reinforces that officers have probable cause to arrest individuals who disobey lawful traffic directions and resist arrest, even in non-criminal contexts. It also clarifies that the exception to the probable cause requirement for retaliatory arrest claims is narrow and requires objective evidence of disparate treatment.