Teresa A. Pyles v. Robert S. Raisor, Ray L. Sabbatine

NATHANIEL R. JONES, Circuit Judge,

dissenting.

I disagree with the majority’s assertion that, based on the facts in the record before this court, the existence of Officer Raisor’s probable cause to arrest Teresa Pyles is a question where “there is only one reasonable determination possible.” Majority Op. at 1215 (citing Yancey v. Carroll County, 876 F.2d 1238, 1243 (6th Cir.1989)). Indeed, the facts presented to this court raise serious questions as to the existence of probable cause.

No one disputes that at the time the unlawful transaction allegedly took place, the auditorium in Rupp Arena was unlit because a rock concert was about to begin. The lower court determined that neither Officer Raisor nor any of the other officers present actually witnessed Pyles give the beer to Annabell Haars; nor did any of the officers actually see Haars drink the beer. See J.A. at 69. In fact, based on the record before this court, the only evidence that arguably could have provided a basis for probable cause was Officer Raisor’s testimony that during his questioning of Pyles’ party, he witnessed Haars “slide” a cup of beer toward Pyles with her (Haars’) foot.

Contrary to the majority’s claim, the district court did not find that Raisor had probable cause to conclude that Pyles has supplied Haars with beer. See J.A. at 68-72. This ease is before this court on appeal from the district court’s grant of Pyles’ motion for a directed verdict pursuant to Federal Rule of Civil Procedure 50(a). See J.A. at 37. Accordingly, the district court was bound to view all the evidence, and reasonable inferences drawn therefrom, in the light most favorable to Officer Raisor. See Agristor Leasing v. A.O. Smith Harvestore Prods. Inc, 869 F.2d 264, 268 (6th Cir.1989). Evaluating the evidence under this standard, the lower court correctly concluded that “Officer Raisor arguably had probable cause to believe that someone in [Pyles’] party — not necessarily even [Pyles] herself — had committed an offense.” J.A. at 69 (emphasis added).1 A jury would not, however, have been bound by this standard, but would have applied the *1217“preponderance of the evidence” standard, generally applicable in civil cases. Under this less rigid standard, a reasonable juror certainly could have determined that Officer Raisor lacked probable cause to arrest Pyles for the suspected state-law misdemeanor crime of procuring alcohol for a minor, and could accordingly have found that Raisor violated Pyles’ right not to be arrested for a misdemeanor absent probable cause by the arresting officer. See Adams v. Metiva, 81 F.3d 375, 383 (6th Cir.1994) (“An arrest must be predicated on probable cause that a crime has been committed.”) (citing Henry v. United States, 361 U.S. 98, 80 S.Ct. 168, 4 L.Ed.2d 134 (1959)).

Accordingly, while I agree that an alleged violation of Kentucky law is an inappropriate basis for directing a verdict in favor of Pyles in this section 1983 action, I strongly believe that this conclusion should not bring this litigation to an end as the majority has done. Rather, I would vacate the directed verdict in favor of Pyles and remand this case in order to allow a jury to determine whether Officer Raisor’s actions violated Pyles’ right, under federal law or the Constitution, not to be arrested without probable cause. I therefore dissent.

. Addressing Officer Raisor’s claim that he was entitled to qualified immunity because he had probable cause to believe that a misdemeanor had been committed in his presence, the lower court stated the following:

This argument is without merit. In Kentucky, a warrantless arrest on misdemeanor charges is lawful only if the offense is committed in the arresting officer’s presence. The evidence in this case is clear that neither Officer Raisor nor his fellow officers witnessed many crucial elements of the offense charged. Although Officer Raisor arguably had probable cause to believe that someone in Plaintiff’s *1217party — not necessarily even Plaintiff herself— had committed an offense, mere probable cause that a misdemeanor offense has occurred is insufficient grounds for arrest.

J.A. at 69. Thus, although the district court may have erred in applying the standard for establishing a claim under 18 U.S.C. § 1983, the majority has clearly misstated the court's factual findings with respect to probable cause.