Hansen v. Schaefer

CourtDistrict Court, D. Nevada
DecidedMarch 24, 2022
Docket2:19-cv-02234
StatusUnknown

This text of Hansen v. Schaefer (Hansen v. Schaefer) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hansen v. Schaefer, (D. Nev. 2022).

Opinion

1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 NICHOLAS HANSEN, Case No.: 2:19-cv-02234-APG-BNW

4 Plaintiff, Order

5 v. [ECF Nos. 55, 60]

6 THEODOR SCHAEFER, DARREL DAVIES, JOE LOMBARDO, CAESARS 7 ENTERTAINMENT CORPORATION, and CORNER INVESTMENT COMPANY, 8 LLC,

9 Defendants.

10 Plaintiff Nicholas Hansen sues Caesars Entertainment Corporation and Corner 11 Investment Company, LLC (collectively, Caesars) for false imprisonment. Hansen argues that 12 Caesars was complicit in his improper detention when he was arrested by police officers. The 13 officers held Hansen in a security room located in the Flamingo Hotel (which Caesars owns) 14 while they completed his arrest paperwork.1 Caesars moves for summary judgment, arguing that 15 the officers had probable cause to arrest Hansen, which is a defense to false imprisonment. 16 Hansen responds that the officers lacked probable cause to arrest him because they 17 misunderstood the ordinance under which he was arrested, and that even if there was probable 18 cause, he was falsely imprisoned pre-arrest. 19 I grant Caesars’s motion. Even viewing the evidence in the light most favorable to 20 Hansen, a reasonable jury could not conclude that the officers lacked probable cause to arrest 21 him, or that he was falsely imprisoned pre-arrest. 22 23

1 I will address Hansen’s claims against the officers by separate order. 1 I. BACKGROUND 2 In 2017, Las Vegas Metropolitan Police Department (Metro) officers were in the 3 surveillance room of the Flamingo Hotel where they watched Hansen through a live security- 4 camera feed. ECF No. 82-1 at 3. Hansen was standing on the sidewalk outside the Cromwell

5 Hotel, holding a large sign, and advertising for local strip clubs. Id. at 2; ECF No. 60-10 at 1:14, 6 2:33. His sign read “[s]trip clubs[,] it is unavoidable[,] [i]t is your destiny,” on one side, and 7 “[h]urray for boobies,” on the other. ECF No. 60-10 at 1:14, 2:33. Officer Schaefer testified that 8 Hansen stood “in front of [an] escalator, almost right in line with one of the handrails.” ECF No. 9 82-2 at 3. Officer Davies testified that, because the pedestrian zone was “busy” and there were 10 “a lot of people along the boulevard,” Hansen was “impeding the flow of traffic,” particularly on 11 the escalator. ECF No. 82-1 at 5. 12 After the officers saw that “multiple people [were] going around [Hansen,] . . . causing a 13 backup [of] people on the escalator,” they concluded that the situation risked injury to passersby, 14 so they arrested him under Clark County Code of Ordinances (CCCO) § 16.11.090.2 Id.; ECF

15 No. 60-1 at 1. The officers held Hansen in a security room located in the nearby Flamingo Hotel 16 while they completed his arrest paperwork. ECF No. 60-1 at 2; ECF No. 82-2 at 6. Eventually, 17 Hansen was transported to the Clark County Detention Center. ECF No. 82-1 at 6. Hansen 18 claims that he was falsely imprisoned while in custody in the Flamingo Hotel security room. 19 / / / / 20 / / / / 21

22 2 The Metro officers cited Hansen for two ordinance violations under CCCO § 16.11: obstructing a public sidewalk and storing materials on a public sidewalk. ECF No. 61-2 at 2. I need not 23 reach the second violation because I conclude that the Metro officers had probable cause to arrest Hansen for obstruction. 1 II. ANALYSIS 2 Summary judgment is proper where a movant shows that “there is no genuine dispute as 3 to any material fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 4 56(a). A fact is material if it “might affect the outcome of the suit under the governing law.”

5 Anderson v. Liberty Lobby, 477 U.S. 242, 249 (1986). A dispute is genuine if “the evidence is 6 such that a reasonable jury could return a verdict for the nonmoving party.” Id. at 248. The 7 moving party bears the initial burden of informing the court of the basis of its motion and the 8 absence of material fact. Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). When the 9 nonmoving party has the burden of proof at trial, the moving party need only point out “that 10 there is an absence of evidence to support the nonmoving party’s case.” Celotex, 477 U.S. at 325; 11 see also Fairbank v. Wunderman Cato Johnson, 212 F.3d 528, 532 (9th Cir. 2000) (stating that 12 the moving party can meet its initial burden by “pointing out through argument . . . the absence 13 of evidence to support plaintiff’s claim”). 14 Once the moving party carries its burden, the nonmoving party must “make a showing

15 sufficient to establish the existence of [the disputed] element to that party’s case.” Celotex, 477 16 U.S. at 322. I view the evidence and reasonable inferences in the light most favorable to the 17 nonmoving party. James River Ins. Co. v. Hebert Schenk, P.C., 523 F.3d 915, 920 (9th Cir. 18 2008). 19 Under Nevada law, false imprisonment is “an unlawful violation of the personal liberty of 20 another, and consists [of] confinement or detention without sufficient legal authority.” Lerner 21 Shops of Nev., Inc. v. Marin, 423 P.2d 398, 400 (Nev. 1967). “There is no false imprisonment 22 where [an] accused is imprisoned under [a] valid legal process.” Nelson v. City of Las Vegas, 665 23 P.2d 1141, 1144 (Nev. 1983) (internal quotation marks omitted). An arrest supported by 1 probable cause amounts to detention under a valid legal process, and it cannot give rise to a 2 claim for false imprisonment. See Hernandez v. City of Reno, 634 P.2d 668, 671 (Nev. 1981) 3 (affirming dismissal of false imprisonment claims where police had probable cause to arrest). 4 “Probable cause exists when, under the totality of the circumstances known to the

5 arresting officers (or within the knowledge of the other officers at the scene), a prudent person 6 would believe the suspect had committed a crime.” Blankenhorn v. City of Orange, 485 F.3d 7 463, 471 (9th Cir. 2007) (quotation omitted). “[P]robable cause means [a] fair probability, not 8 [a] certainty or even a preponderance of the evidence.” United States v. Gourde, 440 F.3d 1065, 9 1069 (9th Cir. 2006) (en banc) (quotation omitted). It is “not a high bar.” Kaley v. United States, 10 571 U.S. 320, 338 (2014). 11 Even reasonable mistakes of law and fact can justify probable cause. See, e.g., Heien v. 12 N.C., 574 U.S. 54, 60-62 (2014) (“To be reasonable is not to be perfect . . . .”). For example, “if 13 officers with probable cause to arrest a suspect mistakenly arrest an individual matching the 14 suspect’s description, neither the seizure nor an accompanying search of the arrestee would be

15 unlawful.” Id. at 61. The inquiry is based on the information “known to the arresting officer at 16 the time of the arrest.” Devenpeck v. Alford, 543 U.S. 146, 152 (2004). The inquiry is 17 objective. Id. at 153 (“Our cases make clear that an arresting officer’s state of mind (except for 18 the facts that he knows) is irrelevant to the existence of probable cause.”). In civil cases, the 19 existence of probable cause is generally a question of fact for the jury.

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Related

Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Devenpeck v. Alford
543 U.S. 146 (Supreme Court, 2004)
Torres v. Commonwealth of PR
485 F.3d 5 (First Circuit, 2007)
United States v. Micah J. Gourde
440 F.3d 1065 (Ninth Circuit, 2006)
Lerner Shops of Nevada, Inc. v. Marin
423 P.2d 398 (Nevada Supreme Court, 1967)
Hernandez v. City of Reno
634 P.2d 668 (Nevada Supreme Court, 1981)
James River Insurance v. Hebert Schenk, P.C.
523 F.3d 915 (Ninth Circuit, 2008)
Kaley v. United States
134 S. Ct. 1090 (Supreme Court, 2014)

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Bluebook (online)
Hansen v. Schaefer, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hansen-v-schaefer-nvd-2022.