Background
Cody Henderson sued the Village of New Holland, Ohio, and two police officers under 42 U.S.C. § 1983 after several encounters with local police. On September 13, 2022, Chief William Lawless and Officer Darnell Pate stopped Henderson after Pate’s radar gun registered his car traveling 47 miles per hour near the village’s 35-mile-per-hour zone. Henderson maintained that he had slowed to 34 miles per hour before entering the village.
On September 22, the officers again stopped Henderson because his vehicle still had expired registration tags. They impounded the car and conducted an inventory search, forcing open a locked tote that contained hemp, CBD, and similar substances. The officers arrested Henderson for obstructing official business after he tried to prevent access to the car, repeatedly approached the officers, and loudly protested the search. Prosecutors later dismissed the charges, apparently because the substances were legal hemp products.
The district court granted summary judgment to the village and dismissed most claims against Lawless, but allowed Henderson’s Fourth Amendment and Ohio malicious-prosecution claims to proceed. Lawless brought an interlocutory appeal from the denial of qualified immunity.
The Court’s Holding
The Sixth Circuit reversed, holding that Lawless committed no Fourth Amendment violation. The September 13 stop was supported by probable cause because Lawless visually observed Henderson approaching at an excessive speed and reasonably relied on Pate’s radar reading. Even accepting Henderson’s assertion that he had slowed before entering the village, any mistake about where his speed was measured was reasonable and therefore did not defeat probable cause.
The September 22 inventory search was also constitutional. The officers lawfully impounded the repeatedly unregistered vehicle under a village ordinance and searched it pursuant to a policy requiring a complete inventory of an impounded vehicle’s contents. The policy reasonably authorized opening the locked tote, and deficiencies in the officers’ after-the-fact inventory paperwork did not show that the search was a pretext for investigation.
The court further held that Lawless had probable cause to arrest Henderson for obstructing official business. Henderson engaged in affirmative conduct that delayed the lawful inventory search, including attempting to close and lock the car, walking toward the officers despite instructions to remain away, and loudly trying to stop the search. Because probable cause also existed for the arrest, Henderson’s Ohio malicious-prosecution claim failed as a matter of law.
Key Takeaways
- An officer may have probable cause for a traffic stop based on visual observations and a radar reading even if the driver disputes whether the violation actually occurred, provided any factual mistake was reasonable.
- Imperfect compliance with inventory-search paperwork requirements does not itself violate the Fourth Amendment absent evidence that officers used the inventory process as a pretext for an investigatory search.
- A policy requiring a complete inventory of a vehicle’s contents may authorize officers to open closed or locked containers even without expressly mentioning such containers.
- Under Ohio obstruction law, approaching officers, attempting to prevent access to a vehicle, and engaging in loud, delaying conduct can constitute affirmative acts supporting probable cause.
Why It Matters
The decision reinforces that the Fourth Amendment requires reasonable police conduct, not factual perfection. A driver’s competing account of a suspected traffic violation will not necessarily create a triable issue when the officer’s probable-cause determination remains reasonable under either version of events.
The ruling also gives law-enforcement agencies and civil-rights litigators guidance on inventory searches: standardized policies must constrain officer discretion, but courts will not constitutionalize every administrative detail. The central inquiry remains whether officers lawfully took custody of the vehicle and conducted a genuine inventory rather than a pretextual evidence search.