Conner v. Heiman

When the material facts are undisputed by the parties and the dispute is only what inferences may properly be drawn from the facts, a court must decide the question of qualified immunity as a matter of law; a jury's possible finding that more reasonable inferences may have been drawn from the facts is irrelevant if the court finds that defendants acted on reasonable conclusions based upon the circumstances and settled law.

Conner was a patron of Harrah's Operating Company who was investigated and arrested for theft by Nevada Gaming Control Board agents after he refused to return an overpayment received as a result of betting at Harrah's. Conner brought suit against the agents under 42 U.S.C. § 1983 for violation of his Fourth Amendment rights. The District Court denied summary judgment for defendants, ruling that the defendants were not entitled to qualified immunity because a jury could find that the plaintiff lacked the mens rea necessary for theft. The Ninth Circuit held that, so long as the defendants' actions were reasonable under the totality of circumstances and under settled law, it is irrelevant that a jury could have found a more reasonable course of action. Because there was no dispute as to material facts of the arrest and the only disputes involved what inferences could be drawn from those facts, the District Court should have decided the question of immunity as a matter of law. Finding that the defendants' conclusion that they had probable cause to arrest plaintiff for theft was reasonable under the circumstances, the Court ruled that they were entitled to qualified immunity. REVERSED and all claims against defendants DISMISSED.