Cody Henderson v. Village of New Holland

Summary

The Sixth Circuit reversed the district court's denial of qualified immunity to New Holland police chief William Lawless on Cody Henderson's surviving Fourth Amendment and malicious-prosecution claims. The court held that the officers had probable cause for the September 13 speeding stop based on radar confirmation and the reasonable-mistake doctrine, that the September 22 impoundment and inventory search of Henderson's car — including forcing open a locked tote — complied with the Fourth Amendment despite imperfect paperwork compliance with the village's inventory policy, and that probable cause supported Henderson's arrest for obstructing official business based on his video-recorded affirmative acts of interference. Because no constitutional violation occurred at any juncture, the court did not reach the clearly-established prong of the qualified-immunity analysis, and the state-law malicious-prosecution claim failed for lack of the probable-cause element.