Case Explained: 26a0225p.06

Court: United States Court of Appeals for the Sixth Circuit Filed: 2026-08-07 The Sixth Circuit reversed the district court’s denial of qualified immunity to Officer William Lawless in this Fourth Amendment civil rights case brought under 42 U.S.C. § 1983. The court held that no constitutional violation occurred at any of the three challenged junctures: the initial traffic stop, the inventory search, and the subsequent arrest for obstruction of official business. Regarding the September 13 traffic stop, the court applied the probable cause standard, noting that while there is some circuit split on whether reasonable suspicion or probable cause is required for civil traffic violations, the officers satisfied the higher probable cause standard. The court ruled that an officer’s reasonable mistake regarding a driver’s speed does not defeat probable cause under *Heien v. North Carolina*. Because Officer Lawless reasonably relied on radar gun readings and visual observations indicating speeding, the stop was lawful regardless of whether Henderson actually exceeded the speed limit at the exact moment of measurement. Regarding the September 22 inventory search, the court applied the exception for warrantless inventory searches established in *Colorado v. Bertine*. The court found the impoundment lawful because it was based on a standardized criterion (impounding vehicles connected to the commission of a crime, specifically driving with expired registration) rather than suspicion of criminal activity. The court further held that the search did not violate the Fourth Amendment despite minor deviations from department policy regarding paperwork and the opening of a locked container. Citing *United States v. Hockenberry* and *Whren v. United States*, the court reasoned that imperfect compliance with internal policies does not render a search unconstitutional absent evidence that the officers used the inventory process as a pretext for an investigatory search. The policy to conduct a “complete physical inventory” was sufficient to authorize opening closed containers. Regarding the arrest for obstruction of official business, the court applied Ohio law and Sixth Circuit precedent requiring an “affirmative act” that hampers or impedes a public official’s lawful duties. The court found probable cause existed because Henderson engaged in loud, boisterous conduct, refused to sit on the curb as directed, walked toward officers during the search, and attempted to lock his vehicle to prevent access. These actions constituted an affirmative act intended to obstruct the inventory search, satisfying the elements of the offense under Ohio Revised Code § 2921.31(A). Finally, the court held that Henderson’s state-law malicious prosecution claim failed as a matter of law because it required a showing of lack of probable cause for the underlying arrest, which the court had already determined existed. The practical consequence is that Officer Lawless is granted qualified immunity, and the case is remanded to the district court with instructions to dismiss the surviving claims against him. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.