CINCINNATI, OHIO — The U.S. Court of Appeals for the Sixth Circuit has affirmed in part and reversed in part a lower court’s ruling in a civil rights lawsuit brought by Amanda and Patrick Caton against two Loveland police officers and the City of Loveland, Ohio.
The lawsuit stems from a February 2020 incident in which Amanda Caton, an off-duty Cincinnati police officer, was pulled over and arrested by Loveland Officer Jacob Salamon on suspicion of operating a vehicle while intoxicated. She was later acquitted at trial.
After the arrest, the Catons filed suit under 42 U.S.C. § 1983 and Ohio state tort law, alleging constitutional violations, malicious prosecution, false arrest, and other misconduct. The district court allowed several claims to proceed, prompting the officers and the city to file an interlocutory appeal.
In its opinion, the Sixth Circuit ruled that Amanda Caton’s constitutional claims against Officer Salamon for prolonging the traffic stop and making the arrest without probable cause could move forward. The court noted that a jury could find Salamon lacked reasonable suspicion to extend the stop or probable cause to arrest Caton, particularly in light of disputed facts about her appearance and behavior during the stop.
The court also upheld related state-law claims for false arrest and malicious prosecution against Salamon, citing evidence that he may have acted in bad faith by arresting Caton without proper justification.
However, the panel reversed the denial of qualified immunity for Officer Shawn Parks, who was present during the arrest but did not participate in the decision-making. The court found no clearly established precedent imposing liability on Parks for his limited role.
The court also reversed the Catons’ claim that the officers violated the Fourth Amendment by stepping onto their driveway after the arrest. It found that there was no search or seizure and that the officers’ conduct was consistent with standard law enforcement procedures.
A failure-to-train claim against the City of Loveland, based on Parks’ conduct, was also dismissed. Other failure-to-train claims related to Officer Salamon remain for the district court to consider.
The Catons’ claim for intrusion upon seclusion was not resolved; the appellate court vacated the ruling and sent it back to the lower court to determine whether the officers’ conduct met the threshold for overcoming state-law immunity.
The case will proceed in the Southern District of Ohio on the remaining claims.
