Horocofsky v. City of Lawrence, Kansas

Court of Appeals for the Tenth Circuit·Decided July 24, 2026·No. 25-3024·Published

Opinion

Appellate Case: 25-3024 Document: 70-1 Date Filed: 07/24/2026 Page: 1 FILED United States Court of Appeals PUBLISH Tenth Circuit

UNITED STATES COURT OF APPEALS July 24, 2026 Christopher M. Wolpert FOR THE TENTH CIRCUIT Clerk of Court _________________________________

BOBBIE JO HOROCOFSKY,

Plaintiff - Appellant,

v. No. 25-3024

CITY OF LAWRENCE, KANSAS; CHARLES B. COTTENGIM; KIMBERLEE A. NICHOLSON,

Defendants - Appellees. _________________________________

Appeal from the United States District Court for the District of Kansas (D.C. No. 2:20-CV-02529-EFM) _________________________________

Cheryl A. Pilate, Morgan Pilate LLC, Kansas City, Missouri (Sarah A. Brown, Brown, Curry & Duggan, LLC, Kansas City, Missouri, with her on the briefs), for Plaintiff- Appellant.

Michelle R. Stewart, Hinkle Law Firm, LLC, Lenexa, Kansas, for Defendants-Appellees. _________________________________

Before HOLMES, Chief Circuit Judge, HARTZ, Circuit Judge, and GARCIA, * District Judge. _________________________________

HARTZ, Circuit Judge. _________________________________

The Honorable Matthew L. Garcia, District Judge, United States District *

Court, District of New Mexico, sitting by designation. Appellate Case: 25-3024 Document: 70-1 Date Filed: 07/24/2026 Page: 2

Plaintiff Bobbie Jo Horocofsky alleges that she was raped by a law-school

classmate. But officers of the City of Lawrence Police Department (LPD) ended up

investigating her for filing a false report, and she was charged on three counts of

making false accusations against the alleged rapist. After those charges were

dismissed, Plaintiff sued LPD Officers Charles Cottengim and Kimberlee Nicholson

(Defendants) and the City of Lawrence under federal civil-rights statutes and state

law. 1 Three years into the litigation, she also sought to add a claim that Defendants

violated her Fourth Amendment rights by searching her phone.

The district court dismissed all the claims and denied Plaintiff’s motion to add

a Fourth Amendment claim. On appeal we are asked to review only (1) the dismissals

for failure to state a claim of the federal civil-rights claims of malicious prosecution

and conspiracy against Defendants, (2) the district court’s refusal to allow Plaintiff to

amend her complaint, (3) the grant of summary judgment against her on an equal-

protection claim against Defendants, and (4) the grant of summary judgment against

her on several state-law claims against Defendants and the City. Exercising

jurisdiction under 28 U.S.C. § 1291, we largely affirm.

We hold that the malicious-prosecution claim failed to adequately allege that

Defendants were responsible for the prosecution; that the conspiracy claim failed to

adequately allege that Defendants agreed with anyone to violate Plaintiff’s rights;

and that Plaintiff did not demonstrate good cause to file an amended complaint after

1 Also sued were LPD Officer Daniel Affalter and the University of Kansas, but the parties have stipulated to their dismissal.

2 Appellate Case: 25-3024 Document: 70-1 Date Filed: 07/24/2026 Page: 3

the court-ordered deadline for amendments. As for the equal-protection claim, we

hold that Plaintiff failed to adequately show that Defendants treated her differently

from anyone similarly situated to her or that circumstantial evidence supported an

inference of discrimination.

Ordinarily, however, a district court should not rule on state-law claims before

it on supplemental jurisdiction after disposing of the federal claims before trial. We

therefore remand for the district court to determine whether it should have declined

to exercise supplemental jurisdiction over those claims.

I. BACKGROUND

Two documents will dominate our discussion: Plaintiff’s First Amended

Complaint (the Complaint) and the probable-cause affidavit submitted by Officer

Cottengim in support of the warrant for Plaintiff’s arrest for making false accusations

(the Affidavit). 2 For the purpose of providing the background for our discussion, we

will rely primarily on the Complaint but supplement it with undisputed facts in the

record.

A. Factual Background

On September 27, 2018, Plaintiff, a student at the University of Kansas School

of Law, went out to drink with fellow students, including Joel Thompson. Thompson

2 The operative complaint, Plaintiff’s First Amended Complaint, appears at Aplt. App., Vol. 1 at 86–156. This opinion will reference it simply as the Complaint, and citations to it will provide the page of the Complaint. Similarly, the Affidavit appears at Aplt. App., Vol. 9 at 2363–69, and our citations will provide the page of the Affidavit.

3 Appellate Case: 25-3024 Document: 70-1 Date Filed: 07/24/2026 Page: 4

was “the best friend of her on again, off-again boyfriend, Kriston Guillot.” Compl.

at 10.

Early the next morning she “woke up in a strange bed” naked with “bruises on

her body.” Id. at 9. “[S]he did not initially recognize” the man “in bed with her” but

eventually determined that it was Thompson. Id. “She knew he’d had sex with her,

even though she was far too intoxicated to consent.” Id. at 9–10.

At around 6 a.m. Plaintiff was about to text her close friend, Courtney Hurtig,

when she saw that four hours earlier she had texted her, saying that she had “‘fucked

up’ and ‘slept with Joel.’” Id. at 10. Plaintiff “had no memory of sending that

message.” Id. Plaintiff had also texted Hurtig: “It’s all good . . . this was a fuck up

though I literally made him stop having sex and was like oh no what will Kriston

say.” Id. at 13 (cleaned up). Hurtig asked, “What happened to it being gross and he

slept with half the law school?! Dirty. Dick.” Aff. at 3 (internal quotation marks

omitted). Plaintiff responded, “I know . . . maybe I should just start an antibiotic” and

“I know! It is gross . . . he’s actually really good at sex though.” Id. (internal

quotation marks omitted).

Later that morning Plaintiff returned home and texted Hurtig: “Get here fast --

I’m literally about to have a breakdown.” Compl. at 10 (internal quotation marks

omitted). When Hurtig arrived, she saw Plaintiff’s bruises, noticed that Plaintiff was

unusually upset, and suspected that Plaintiff had been raped. 3

In Kansas, rape includes “[k]nowingly engaging in sexual intercourse with a 3

victim . . . when the victim is incapable of giving consent because of the effect of any

4 Appellate Case: 25-3024 Document: 70-1 Date Filed: 07/24/2026 Page: 5

The next day Plaintiff’s memories began to return. She told Hurtig, “I don’t

know . . . I don’t know if it’s rape. I’m so embarrassed,” and she texted Hurtig’s

boyfriend, “I’m pretty sure it was borderline date rape and I have the bruises and

statements to prove it.” Id. at 11–12 (internal quotation marks omitted). After

Plaintiff “acknowledge[d] that she may have been raped,” Hurtig called the LPD “and

sa[id] that her friend [was] ready to report a rape.” Id. at 12.

LPD Officer Daniel Affalter asked Plaintiff and Hurtig to meet at Lawrence

Memorial Hospital. The two women met with Affalter and Defendants. Plaintiff “told

Affalter that she had been raped the day before,” but “she did not want to press

charges.” Id. at 13.

Plaintiff and Hurtig provided their phones to the officers to examine.

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Horocofsky v. City of Lawrence, Kansas, (10th Cir. 2026).

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