Martin v. Martinez

Dist. Ct. did not err in granting defendants-police officials’ motion for partial summary judgment, in section 1983 action alleging that defendants unlawfully stopped his car in traffic stop and subjected him to false arrest and unlawful search. While plaintiff could receive damages for unlawful stop, since trial court had previously granted defendant’s motion to suppress evidence based on said stop, plaintiff could not receive damages for false arrest and for unlawful search, where plaintiff’s arrest (and subsequent incarceration) was supported by probable cause when defendants found gun and drugs in defendant’s car. Moreover, given jury’s verdict for defendants as to plaintiff’s false arrest and unlawful search claims, plaintiff could only receive damages for his brief seizure occasioned by stop of his car prior to officers seeking production of plaintiff’s driver’s license, and that jury accounted for such brief seizure by awarding plaintiff one dollar in nominal damages on his unlawful stop claim.