Flowers v. Fiore case brief

Flowers v. Fiore case brief summary
359 F.3d 24 (2004)

CASE SYNOPSIS

Appellant detainee sued appellee police officers, alleging that the officers' stop and detention of the detainee constituted an arrest without probable cause in violation of the detainee's constitutional protection against unreasonable seizures. The detainee appealed the order of the United States District Court for the District of Rhode Island which granted summary judgment to the officers.

CASE FACTS
One officer received a report of a threat of violence at a residence involving two African-American males in a gray or black vehicle being sent to the residence with a gun. The officer subsequently observed the detainee, an African-American male, driving near the residence in a gray vehicle and contacted the other officers for backup prior to stopping the vehicle. With weapons drawn, the officers handcuffed the detainee and placed him in a police vehicle, and the detainee was released after the officers discovered nothing incriminating in the detainee's vehicle.

DISCUSSION

• The appellate court held that, while it was a close case, the officers acted reasonably in stopping the detainee for investigatory purposes, and the officers' conduct did not constitute an actual arrest requiring probable cause. 
• The report of a threat of armed violence justified the officers' actions in drawing their weapons and restraining the detainee prior to conducting their investigation, and the relatively brief duration of the investigation was not unreasonable. 
• Further, the immediacy and gravity of the reported threat created a reasonable suspicion of criminal activity by the detainee under the circumstances.

CONCLUSION
The order granting summary judgment to the officers was affirmed.

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