Eleventh Circuit Holds Officer Failed to Take Reasonable Steps to Address Exculpatory Information

Jeffrey Cozzi was arrested for the robbery of one pharmacy and the attempted robbery of another. However, Cozzi was released after the police found no evidence linking him to the crimes. Cozzi sued Officer Cedrick Thomas, the City of Birmingham, Alabama, and several other law enforcement officers alleging a violation of his Fourth Amendment right to be free from unlawful arrest. Cozzi v. City of Birmingham, 892 F.3d 1288 (11th Cir. 2018), cert. denied sub nom. Thomas v. Cozzi, 2018 WL 4539139 (U.S. 2018). The district court granted summary judgment to all defendants except for Officer Thomas. On appeal, Officer Thomas argued that he was entitled to qualified immunity because he had, at a m

Suspected Burglary Creates “Exigent Circumstances” Which Permit a Warrantless Search

In 2011, Officer Todd Raible was driving an unmarked patrol car through a neighborhood that had been experiencing an increase of daytime burglaries. Officer Raible witnessed two individuals acting suspiciously between two homes and requested backup prior to approaching the suspects. Officer Jorge Carvajal responded to Officer Raible’s request for backup and, when he arrived, the officers approached the individuals. The suspects ran to the back of a home and, after a short scuffle, the suspects were handcuffed. Officer Raible then entered the home’s back door and stepped through a small vestibule to a second door, which led to the home’s interior. Without crossing the threshold, Officer Rai

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