Wright v. State

John Wright (plaintiff) sued Ray Houghton, the state of Montana, the city of Bozeman, and a police officer (collectively, the state) (defendants) for false arrest after Wright was arrested while attempting to renew his driver’s license. Wright was required to pass a written exam, complete an application, and take a driving test to renew his license. Although Montana law no longer required the disclosure of a Social Security number on the driver’s-license application, the employee who processed Wright’s application still requested Wright’s Social Security number. Wright refused to provide his Social Security number and was assigned a random number for purposes of the application. Wright returned to the licensing office for the driving test later that day and brought proof of insurance. Houghton, the examiner, rejected Wright’s proof of insurance and refused to administer the driving test. Wright got into an argument with Houghton, and Houghton told Wright to leave and not come back that day. Wright returned to the licensing office a while later and, without first speaking to or interacting with Wright, Houghton called the police. The police arrested Wright for disorderly conduct and criminal trespass after Wright refused an officer’s request to leave the premises. Wright was released on bail and returned to the licensing office a few days later, showed proof of insurance, took the driver’s test, and was issued a new driver’s license. The charges against Wright were dismissed. Wright filed suit against the state for false arrest. The state filed a motion for summary judgment. Wright failed to submit any evidence in opposition to the state’s motion, and the trial court granted the motion. Wright appealed to the Montana Supreme Court, arguing that summary judgment was improper because the question of whether his arrest was supported by probable cause was a question of fact for the jury to decide.