John Woodruff v. Luigi Ragazzoni, et al.

District Court, N.D. Alabama·Decided September 2, 2026·No. 2:23-cv-01155·Unknown

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION

JOHN WOODRUFF, Plaintiff,

v. Case No. 2:23-cv-1155-CLM

LUIGI RAGAZZONI, et al., Defendants.

MEMORANDUM OPINION Plaintiff John Woodruff was twice arrested by Shelby County Sheriff’s Deputies during August and September 2021. Both times, deputies impounded Woodruff’s truck and searched its contents. Woodruff now sues the arresting deputies, Luigi Ragazzoni and David Pressley, for violating his Fourth Amendment rights against wrongful search and seizure. (See Doc. 9). Ragazzoni and Pressley move for summary judgment. (Docs. 44, 45). For the reasons stated within, the court GRANTS Ragazzoni and Pressley’s motion (doc. 44, 45). STATEMENT OF THE FACTS Ragazzoni and Pressley contend that their searches of Woodruff’s truck were valid inventory searches of Woodruff’s impounded vehicle. While officers “generally need a warrant to conduct a search, they do not need a warrant to search an impounded car if they (1) had the authority to impound the car, and (2) followed department procedures governing inventory searches.” See United States v. Isaac, 987 F.3d 980, 988 (11th Cir. 2021). Thus, whether the searches of Woodruff’s truck violated his constitutional rights largely turns on whether Ragazzoni and Pressley followed Shelby County’s policies on impoundment and inventory searches. Below, the court describes the relevant Shelby County policies and then details the two searches of Woodruff’s truck. Because Woodruff is the non-moving party, the court recites the facts in a light most favorable to him. See Cuesta v. Sch. Bd. of Miami-Dade Cnty., Fla., 285 F.3d 962, 966 (11th Cir. 2002). A. Shelby County Policies on Impoundment + Inventory Shelby County currently has two policies relevant to the impoundment of vehicles incident to arrest. The first policy is titled “Towing of Vehicles,” and the second policy is titled “Wrecker Service Procedure.” Under the Wrecker Service Procedure, “[a]ll vehicles operated by persons arrested will be towed unless other arrangements are made.” (Doc. 44-2, p. 12). And under the Towing of Vehicles policy, “[a]ny time a vehicle other than a Sheriff’s Office vehicle is towed, a tow in report (including vehicle inventory) shall be completed on the designated form or software.” (Id., p. 7). In conducting an inventory search, deputies are expected to examine the compartment and containers within the vehicle and to document any existing damage to the vehicle or its equipment. (Id., p. 5). And deputies executing this policy when arresting an occupant of a vehicle “must follow search and seizure[ ] rules and guidelines that have been established under the fourth amendment of the U.S. Constitution.” (Id., p. 8). Both Ragazzoni and Pressley agree that this means that the Fourth Amendment trumps Shelby County’s policies on vehicle searches if the two conflict. (Doc. 44-2, p. 20; Doc. 44-3, p. 12). Different rules apply for towing a vehicle following an out-of-county arrest. “When an out of county arrest is made by a law enforcement agency outside Shelby County and the arrestee is in possession of a vehicle, it is the responsibility of the arresting agency to secure and tow the vehicle to a lot in their jurisdiction.” (Doc. 44-2, p. 8). But “[i]f the arresting agency refuses to tow the vehicle, a supervisor will be contacted and the supervisor will make a decision as to what action will be taken regarding the arrestee’s vehicle. Within reason, the supervisor may elect to dispatch a rotational wrecker from the Sheriff’s Office.” (Id.). B. Search by Ragazzoni Shelby County issued a warrant for Woodruff’s arrest on August 25, 2021, based on Woodruff’s alleged failure to comply with the Alabama Sex Offender Registration and Community Notification Act’s (“ASORCNA”) vehicle registration requirement. (Doc. 44-3, pp. 26–27). After 11:00 PM on August 27, 2021, Woodruff arrived at 24E Fitness in Pelham, Alabama driving his Black 2013 Nissan Frontier Truck. (Doc. 44-4, p. 5; Doc. 44-3, p. 27). While Woodruff was parked in the parking lot, Pelham police officers walked up to the truck. (Doc. 44-4, p. 5). After confirming that Woodruff had an outstanding warrant, the officers required Woodruff to step outside the vehicle. (Id.). The officers then explained that they would wait for a Shelby County deputy to arrive to make an arrest. (Id.). Shelby County dispatched Ragazzoni to execute the warrant. (Doc. 44-4, pp. 55–56). Once on the scene, Ragazzoni confirmed that the identity on the arrest warrant matched Woodruff. (Id.). Ragazzoni then placed Woodruff in the back of his patrol vehicle, impounded Woodruff’s truck, and conducted an inventory search of the truck. (Doc. 44-4, pp. 55–56; Doc. 44-5, p. 4). Ragazzoni also completed an Impoundment Vehicle Report and Arrest Report. (Id.). Woodruff says that he asked Ragazzoni to leave his truck undisturbed so that his family could retrieve the truck around dawn. (Doc. 9, ¶ 18). But Ragazzoni refused. After a tow truck arrived and took custody of Woodruff’s vehicle, Ragazzoni transported Woodruff to the Shelby County Jail. (Doc. 44-5, p. 4). Three days later, Woodruff was released on bond. (Doc. 44-4, p. 15). C. Search by Pressley The next day, Shelby County issued another warrant for Woodruff’s arrest because the State moved to revoke Woodruff’s probation for allegedly committing a new offense. (Doc. 44-5, p. 12). On September 18, 2021, Woodruff visited the Leeds’ Buc-ee’s, which is in Jefferson County, Alabama. (Doc. 44-4, p. 28). After leaving the store, Woodruff returned to his truck and put it in reverse. (Id., p. 29). He then saw police lights come on behind the truck. (Id.). A Leeds Police Officer approached Woodruff and asked him to step outside the truck. (Id.). The Leeds Police Department then notified Pressley about the stop. (Doc. 44-5, p. 35). Dispatch sent a tow truck from Shelby County, and Pressley went to Buc-ee’s to take custody of Woodruff. (Id.). While at Buc-ee’s, Pressley conducted an inventory search by opening compartments and closed items within the truck and looking for any obvious damage to the truck or its contents. (Id., pp. 35–36). According to Woodruff, he asked Pressley to leave his truck and told him that his family would retrieve the truck in three to four hours. (Doc. 9, ¶ 30). Because Pressley’s shift had ended, he contacted Shelby County Sheriff’s Deputy Collin Johnson and transferred custody of Woodruff and his property to Johnson at the old Shelby County Sheriff's Office North Sub Station. (Doc. 44-5, p. 36). Johnson then transported Woodruff to the Shelby County Jail and completed Woodruff’s arrest report. (Id.). STANDARD OF REVIEW Summary judgment is appropriate when there is no genuine dispute of material fact, and the moving party is entitled to judgment as a matter of law. See Fed. R. Civ. P. 56(a). A genuine dispute of material fact exists when “the evidence is such that a reasonable jury could return a verdict for the nonmoving party.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). DISCUSSION The Fourth Amendment protects citizens from “unreasonable searches and seizures.” U.S. CONST. amend. IV. Woodruff alleges that Ragazzoni and Pressley violated this right with the warrantless searches and seizures of his truck. Ragazzoni and Pressley assert the defense of qualified immunity. Qualified immunity protects government officials from being sued in their individual capacities so long as “their conduct ‘does not violate clearly established statutory or constitutional rights of which a reas

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John Woodruff v. Luigi Ragazzoni, et al., (N.D. Ala. 2026).

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