Case Explained: Christopher James Majors v. City of West Des Moines; West Des Moines Police Department; Jason Hatcher

Court: United States Court of Appeals for the Eighth Circuit Filed: 2026-06-25 The eighth-circuit affirmed the district court’s grant of summary judgment in favor of the defendants on all counts of a § 1983 and state law claim alleging unlawful seizure, deprivation of due process, false arrest, and malicious prosecution arising from an arrest warrant based on a domestic disturbance. The court applied de novo review and held that a valid arrest warrant is fatal to these claims unless the plaintiff establishes a *Franks v. Delaware* violation by proving the affiant knowingly or recklessly included false statements and that, excluding those statements, the affidavit would fail to establish probable cause. Viewing the evidence in the light most favorable to the appellant, the court determined that even if the alleged false statements regarding a fractured rib and the review of medical records were excluded, the remaining facts—specifically witness testimony describing physical contact and corroborating injuries to the victim’s ribs—were sufficient to provide probable cause for domestic abuse assault. Consequently, no *Franks* violation occurred, and the claims against the individual officer failed as a matter of law. The court further held that the City of West Des Moines Police Department is not a suable entity under state law and that the appellant presented no independent argument regarding the city’s liability. As a result, the judgment in favor of the defendants stands, and the plaintiff receives no relief. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.