Civil Rights: False Imprisonment-Falsification of Investigation-Deputized Federal Officer Liability

Defendant appealed the denial of her motions to dismiss plaintiffs’ complaints. Defendant, a local police officer who had been deputized as part of a federal sex-trafficking investigation, was alleged to have exaggerated or fabricated facts against plaintiffs, which resulted in their arrest and detention for sex trafficking and related offenses for which they were later acquitted or had their charges dismissed.

Where there was no constitutional or statutorily recognized private cause of action for damages arising from a federal law enforcement officer’s falsification of evidence leading to detention and prosecution of innocent persons, the district court erred by denying defendant’s motion to dismiss the claims against her.

Judgment is reversed.

Farah v. Weyker (MLW No. 73358/Case No. 17-3207 – 18 pages) (U.S. Court of Appeals, 8th Circuit, Stras, J.) Appealed from U.S. District Court, District of Minnesota. Ericksen, J. (Brant S. Levine, of Washington, D.C., for appellant; Barbara L Herwig, of Washington, D.C., Edward Himmelfarb, of Washington, D.C., David G. Cutler, of Washington, D.C., Glenn S. Greene, of Washington, D.C., Paul C. Quast, of Washington, D.C. on brief) (Darron Clarence Knutson of Minneapolis, MN for appellee Yasin Ahmed Farah;  Douglas Altman, of Minneapolis, MN on appellee brief) ( Joshua A. Newville of Minneapolis, MN for appellee Ifrah Yassin) (Andrew Marshall Irlbeck of St. Paul, MN for appellee Hamdi Ali Osman; Paul Applebaum, of St. Paul, MN., Jeffrey S. Storms, of Minneapolis, MN on appellee brief)