Craig Brown et al.v.Georgiacarry.Org, Inc. et al.
Michael Justin Belt and GeorgiaCarry.Org sued the arresting officers after the obstruction charge against Belt was dismissed, asserting a federal malicious-prosecution claim. The trial court granted summary judgment to the officers on the other claims but denied it on qualified immunity for the § 1983 claim. The Court of Appeals held that the officers had arguable reasonable suspicion because an officer testified that he had been told Belt was a shoplifting suspect and a person with a gun; contrary circumstantial evidence did not create a material factual dispute with that direct testimony. The officers therefore were entitled to qualified immunity, and the court reversed the denial of summary judgment. It emphasized that this ruling was limited to qualified immunity on these facts and did not authorize officers to demand identification without a lawful basis to detain a person.
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