Wade v. Miles

In July 1996, police officers Michael Miles and Curt Lysen separately drove to the home of spouses Joel Wade (plaintiff) and Sandra Wade in response to a 911 call from Sandra about being assaulted. When Miles arrived at the home, Joel approached him and said Sandra had hit him with her car. Sandra was in the driver’s seat. Joel later denied having any conversation with Miles. Lysen arrived, and Miles instructed Joel to stay with Lysen. Miles then separately interviewed Sandra and a 15-year-old babysitter named Alena Lomax seated in the car’s passenger seat next to Sandra. Sandra had fresh scratch marks on the upper part of her chest and was visibly distraught. According to Sandra, Joel had struck her face through the open car window and grabbed her chest area, causing the scratches. Sandra denied hitting Joel with the car. Lomax, who had been seated in the car during the incident, confirmed that Sandra had not run over Joel and that Joel had grabbed Sandra and caused the scratch marks. Miles arrested Joel, and the state charged him with fourth-degree assault. Joel was acquitted by a jury based on his claim of self-defense—that is, the jury believed Joel had merely been trying to prevent Sandra from driving away while his arm was in the car. Joel sued Miles and the county (collectively, the state) (defendants), alleging false arrest and false imprisonment among other claims. The trial court granted the state’s motion for summary judgment based in part on Miles’s probable cause to arrest. Joel appealed.