Judge Denise Cote
Croft alleged constitutional and common law tort claims against Greenhope Services for Women Inc. and some of its employees. Croft’s parole required that she attend and complete a residential drug treatment program at Greenhope. One day after a dispute between Croft and a Greenhope employee, other Greenhope employees called the Parole Office and Croft was arrested for violating parole. After spending about four weeks in jail, Croft’s parole was revoked and reissued. She pleaded guilty to violating parole and was discharged to an outpatient program. Croft contended that Greenhope and its employees falsely accused her and caused her arrest. The court granted the defendants summary judgment, holding Croft’s false arrest claim barred because she pleaded guilty to having violated her parole. The court determined that Croft’s guilty plea is conclusive evidence of probable cause to arrest her for violating her parole and therefore declined to examine the defendants’ motives for reporting Croft to the Parole Office. The court further noted that the remaining state law claims of negligence and negligent infliction of emotional distress must be dismissed because these claims must be analyzed under the framework of false arrest.
