On January 28, 2021, the Eighth Circuit Court of Appeals decided Wood v. Wooten[i], in which the court examined whether Deputy Wooten was entitled to summary judgment in a civil suit even if he identified an incorrect offense to the plaintiff. The relevant facts of Wood, taken directly from the case, are as follows:
In the early morning of October 23, 2016, Scott County Deputy Sheriff Toby Haynes pulled Wood over for driving with a broken headlight. Operating a vehicle with a broken headlight at night is illegal in Missouri. §§ 307.040.1, 307.105.1, 307.020(9), RSMo 2016. Checking the records, Haynes discovered an outstanding warrant for an unpaid traffic ticket. Haynes called Justin Wooten, a superior, to tell him he had stopped Wood.
Wooten then called the Sheriff. (At the time, Wood’s estranged wife was rumored to be in a romantic relationship with the Sheriff.) The Sheriff told Haynes to treat Wood the same as everyone else. Wooten relayed this to Haynes.
Haynes drove Wood to the station because of the outstanding warrant. He did not tell Wood he was under arrest. He did not handcuff him. Wood rode in the front seat of the vehicle with Haynes. Arriving at the station, they met Wooten. He and Haynes discussed the broken headlight and the outstanding warrant. Wooten then handcuffed Wood. He informed Wood he was under arrest for driving while intoxicated.[ii]
Wood later sued Deputy Wooten for unlawful arrest under the Fourth Amendment. The district court found that Deputy Wooten had probable cause to arrest Wood, therefore, they granted summary judgment for Wooten and dismissed the case. Wood appealed the grant of summary judgment to the Eighth Circuit Court of Appeals.
The issue before the court of appeals was whether Deputy Wooten had probable cause to arrest Wood.
The court of appeals held that Deputy Wooten did have probable cause to arrest Wood. First, it is undisputed that Wood had an outstanding, valid warrant at the time he was arrested. The court stated
A valid bench warrant provides probable cause for an arrest. Luckes v. Cnty. of Hennepin, 415 F.3d 936, 939 (8th Cir. 2005).[iii]
Second, the court noted that it was undisputed that Wood was driving with a broken headlight, which is a violation of Missouri law. The court stated
An officer has probable cause to make a warrantless arrest when the facts and circumstances are sufficient to lead a reasonable person to believe that the defendant has committed or is committing an offense.” United States v. Torres-Lona, 491 F.3d 750, 755-56 (8th Cir. 2007), citing Beck v. Ohio, 379 U.S. 89, 91, 85 S. Ct. 223, 13 L. Ed. 2d 142 (1964). A traffic violation, no matter how minor, gives probable cause for a traffic stop. United States v. Bloomfield, 40 F.3d 910, 915 (8th Cir. 1994) (en banc). Officers may arrest individuals for minor infractions. See United States v. Burtton, 599 F.3d 823, 829 (8th Cir. 2010), quoting Virginia v. Moore, 553 U.S. 164, 171, 128 S. Ct. 1598, 170 L. Ed. 2d 559 (2008)[iv]
Thus, the court of appeals held that Deputy Wooten had probable cause to arrest Wood based on both the warrant and the broken headlight.
Wood argued that Deputy Wooten lacked probable cause because he told him that he was being arrested for DWI, rather than the warrant or broken headlight. The court stated that this argument failed for two reasons. The first reason was that it was undisputed that Deputy Wooten knew about the warrant and the broken headlight. The court stated
An officer does not have to personally witness the events providing probable cause. He or she may rely on the “collective knowledge of all law enforcement officers involved in the investigation . . . if there is some degree of communication.[v]
The second reason Wood’s argument failed was, as the court stated, a “wrongly-stated reason for an arrest does not nullify an otherwise lawful arrest.”[vi] The court further explained
[T]he validity of the arrest should be judged by whether the arresting officers actually had probable cause for the arrest, rather than by whether the officers gave the arrested person the right reason for the arrest.” United States v. Lester, 647 F.2d 869, 873 (8th Cir. 1981). An officer’s “alleged motive for the arrest cannot vitiate an otherwise lawful arrest.” Peterson v. Kopp, 754 F.3d 594, 599 (8th Cir. 2014), citing Whren, 517 U.S. at 813. Regardless of the officer’s stated reasons, an outstanding warrant can justify an arrest. See Rodgers v. Knight, 781 F.3d 932, 939 (8th Cir. 2015)[vii]
Wood also argued that Deputy Wooten fabricated evidence regarding the DWI and later invoked his Fifth Amendment rights regarding his conduct. However, the court of appeals stated that this conduct, which occurred after the arrest, does not negate the probable cause regarding the outstanding warrant and the broken headlight.
Thus, the court held that since Deputy Wooten had probable cause to arrest Wood for the outstanding warrant and the broken headlight, the district court properly granted Wooten summary judgment.
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Citations
[i] No. 19-3507 (8th Cir. Decided January 28, 2021)
[ii] Id. at 1-2
[iii] Id. at 2 (emphasis added)
[iv] Id. at 3 (emphasis added)
[v] Id. (emphasis added)
[vi] Id. at 4 (citing Devenpeck v. Alford, 543 U.S. 146, 153-54, 125 S. Ct. 588, 160 L. Ed. 2d 537 (2004), quoting Whren v. United States, 517 U.S. 806, 813, 116 S. Ct. 1769, 135 L. Ed. 2d 89 (1996)
[vii] Id. (emphasis added)
