Willie MacDonald v. Anderson Cnty Sheriff's Office

CourtCourt of Appeals for the Fourth Circuit
DecidedSeptember 22, 2022
Docket21-6225
StatusUnpublished

This text of Willie MacDonald v. Anderson Cnty Sheriff's Office (Willie MacDonald v. Anderson Cnty Sheriff's Office) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Willie MacDonald v. Anderson Cnty Sheriff's Office, (4th Cir. 2022).

Opinion

USCA4 Appeal: 21-6225 Doc: 20 Filed: 09/22/2022 Pg: 1 of 7

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 21-6225

WILLIE RAY MACDONALD,

Plaintiff - Appellant,

v.

ANDERSON COUNTY SHERIFF’S OFFICE; SCOTT HILL, in his individual and professional capacity,

Defendants - Appellees.

Appeal from the United States District Court for the District of South Carolina, at Anderson. Henry M. Herlong, Jr., Senior District Judge. (8:19-cv-03212-HMH)

Submitted: August 15, 2022 Decided: September 22, 2022

Before MOTZ, DIAZ, and THACKER, Circuit Judges.

Affirmed by unpublished per curiam opinion.

ON BRIEF: Donald L. Smith, Anderson, South Carolina, for Appellant. Steven M. Pruitt, MCDONALD, PATRICK, POSTON, HEMPHILL & ROPER, LLC, Greenwood, South Carolina, for Appellees.

Unpublished opinions are not binding precedent in this circuit. USCA4 Appeal: 21-6225 Doc: 20 Filed: 09/22/2022 Pg: 2 of 7

PER CURIAM:

Willie Ray MacDonald filed suit against Officer Scott Hill and the Anderson County

Sheriff’s Office (“ACSO”) raising claims under the Fourth Amendment and for

supervisory liability pursuant to 42 U.S.C. § 1983, and claims under state law, including

malicious prosecution, gross negligence, and intentional infliction of emotional distress, in

connection with MacDonald’s arrest for the burglary of a convenience store. The district

court adopted the magistrate judge’s recommendation to grant summary judgment to

Defendants on all claims, and denied MacDonald’s motion under Fed. R. Civ. P. 59(e) to

alter or amend the judgment. On appeal, MacDonald argues that the district court failed to

consider the evidence in the light most favorable to him, that probable cause did not support

his arrest, that Hill was not entitled to qualified immunity, that the ACSO was subject to

supervisory liability, and that the district court erred in denying relief on his state law

claims. For the following reasons, we affirm.

We “review[] de novo the district court’s order granting summary judgment.”

Jacobs v. N.C. Admin. Off. of the Cts., 780 F.3d 562, 565 n.1 (4th Cir. 2015). “A district

court ‘shall grant summary judgment if the movant shows that there is no genuine dispute

as to any material fact and the movant is entitled to judgment as a matter of law.’” Id. at

568 (quoting Fed. R. Civ. P. 56(a)). In determining whether a genuine issue of material

fact exists, “we view the facts and all justifiable inferences arising therefrom in the light

most favorable to . . . the nonmoving party.” Id. at 565 n.1 (internal quotation marks

omitted). However, “the nonmoving party must rely on more than conclusory allegations,

mere speculation, [or] the building of one inference upon another.” Humphreys & Partners

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Architects v. Lessard Design, Inc., 790 F.3d 532, 540 (4th Cir. 2015) (internal quotation

marks omitted). “[T]he relevant inquiry is whether the evidence presents a sufficient

disagreement to require submission to a jury or whether it is so one-sided that one party

must prevail as a matter of law.” Gordon v. Schilling, 937 F.3d 348, 356 (4th Cir. 2019)

(internal quotation marks omitted).

Under § 1983, “allegations that an arrest made pursuant to a warrant was not

supported by probable cause, or claims seeking damages for the period after legal process

issued,” advance a claim of “malicious prosecution.” Brooks v. City of Winston-Salem, 85

F.3d 178, 182 (4th Cir. 1996). Because MacDonald alleged that he was arrested pursuant

to a warrant that lacked supporting probable cause, his claim is properly interpreted as a

malicious prosecution claim. To state a malicious prosecution claim under § 1983, a

plaintiff must establish that (1) the defendant seized the plaintiff “pursuant to legal process

that was not supported by probable cause,” and (2) the criminal proceedings terminated in

the plaintiff’s favor. Durham v. Horner, 690 F.3d 183, 188 (4th Cir. 2012) (internal

quotation marks omitted). Here, it is undisputed that Hill’s procurement of an arrest

warrant caused MacDonald’s arrest. Also, the charges against MacDonald were ultimately

dismissed. Thus, we review whether probable cause supported MacDonald’s arrest.

“Probable cause to justify an arrest means facts and circumstances within the

officer’s knowledge that are sufficient to warrant a prudent person, or one of reasonable

caution, in believing, in the circumstances shown, that the suspect has committed an

offense.” Humbert v. Mayor & City Council of Balt. City, 866 F.3d 546, 555 (4th Cir.

2017) (cleaned up). We evaluate probable cause under an objective standard, considering

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the totality of the circumstances known to the officer at the time of the seizure and without

consideration of the subjective beliefs of the officer regarding the existence of probable

cause. See Smith v. Munday, 848 F.3d 248, 253 (4th Cir. 2017). An investigating “officer

may not disregard readily available exculpatory evidence of which he is aware,” but his

“failure to pursue a potentially exculpatory lead is not sufficient to negate probable cause.”

Wadkins v. Arnold, 214 F.3d 535, 541 (4th Cir. 2000). Although an “officer need not

exhaust every potential avenue of investigation,” he must “assemble individualized facts

that link the suspect to the crime.” Munday, 848 F.3d at 254 (cleaned up). We provide

“great deference to a magistrate judge’s determination of probable cause.” Id.

Our review of the record demonstrates sufficient facts within Hill’s knowledge to

establish probable cause to arrest MacDonald for burglary of the convenience store. At the

time Hill sought the arrest warrant, Hill knew that tobacco products were located behind

the counter of the convenience store. When watching the store’s security footage, Hill saw

the perpetrator climb over the counter to steal tobacco products. While police were on the

scene, the store manager discovered and alerted officers to a tobacco product that contained

dried blood; forensic testing indicated that the blood matched MacDonald. We conclude

that these facts, within Hill’s knowledge, were “sufficient to warrant a prudent person, or

one of reasonable caution, in believing” that MacDonald had committed the burglary. See

Humbert, 866 F.3d at 555 (internal quotation marks omitted).

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Willie MacDonald v. Anderson Cnty Sheriff's Office, Counsel Stack Legal Research, https://law.counselstack.com/opinion/willie-macdonald-v-anderson-cnty-sheriffs-office-ca4-2022.