The case of Dinler v. City of New York
The case of Dinler v. City of New York, 607 F.3d. 923 (2d. Cir. 2010)
Parties: Hacer Dinler (Plaintiff) v. The City of New York (Defendant)
Facts: During the 2004 Republican National Convention, citizens from diverse political and social views took part in demonstrations related to the RNC. However, the demonstrations later lead to mass arrests and detention of some protestors. The plaintiff filed a lawsuit to determine the legality and rights of the NYPD officers to arrest the individual protests. The main complaints for the police actions include false arrests, unreasonable terms of confinement and unlawful detention policies. Thus, the New York City was the defendant against the complaint’s actions.
Prior proceedings: Plaintiffs filed the first lawsuit in late 2004 after the police officers conducted the arrests in question. The plaintiffs filed individual or joint cases seeking to nullify the legality of the arrests made by the police department. The plaintiff’s cases were referred to Judge Francis on October 2, 2007. The court granted and rejected some section of the complainant’s motion for class certification in the initial case by MacNamara v. City of New York. This revealed that the police officers had acted in contrarily the required laws and regulations of conducting arrests.
Issues presented or questions of law:
Did the police the probable cause to arrest protesters during the demonstration?
Was the city’s blanket fingerprinting policy with respect to the arrests lawful and constitutional?
Arguments or objectives of the parties: Based on the case, the plaintiff were required to provide genuine dispute relating to any material facts as indicated in the law. The court is required to provide direction when the determination of probable cause is difficult. On the other hand, the defendant did not challenge that the arresting officers had individualized information of the plaintiff actions. However, the defendant relied on the concept of group probable cause, whereby he police offers have the permission to arrest an entire group of people suspected to engage in an unlawful actions.
Holding/rule of law: According to Rule 56(a) of the Federal Rules of Civil Procedure, the plaintiff was required to prove that there was a genuine issue of material fact to continue with the trial. The plaintiff’s false arrest claims occurred from the mass arrests made by police without any warrants. The circumstance that could justify warrantless arrest is the presence of a probable cause that meets the Fourth Amendment criteria (D'Addario, 2006). However, it was difficult to determine the probable cause among a large group of citizens suspected to engage in unlawful actions.
Rationale: The lack of probable cause would prove that the police arrests were illegal and unconstitutional. The main question was whether during the arrests the individuals were engaging in unlawful actions. The plaintiff contends the arrests based on the time provided by the officers to adhere to the dispersal order. The arresting officers did not allow adequate time for people to leave. Court also questions whether innocent bystanders were informed to leave. The case Jones v. Parmley, in which the police had arrested protestors on a private property, indicated that the police acted unreasonably, since they lack individualized probable cause. The court found out that no police officers could indicate the specific individual responsible for the violation. Thus, without identifying individuals involved in violations could not justify their actions. Based on the stated reasons, the police could not have reasonably determined that the plaintiff and others were acting as a group to commit any unlawful actions (D'Addario, 2006). The court ruled that the police officers must have individualized probable cause in order to validate their arrests. Since, a group probable cause does not justify the violations of law for every individual. The police had no police had not probable cause to conduct the mass arrests or even conduct the blank finger printing of the plaintiff.