Lumpkin v. Brehm

Jessica Lumpkin and Jaylina Lloyd, Plaintiffsv.Detective Lauren Brehm, Shield No. 969, Detective Shkelzen Ahmetaj, Shield No. 6476, Detective “John Doe,” and Sergeant “Richard Roe,” Defendants

OPINION AND ORDER In July 2014, Plaintiffs Jessica Lumpkin and her daughter, Jaylina Lloyd, were arrested for fraudulent credit card use and charged with petit larceny and grand larceny, respectively. The District Attorney subsequently declined to prosecute them. In this resulting litigation, Plaintiffs claim that Defendants lacked probable cause to arrest Plaintiffs, and that Lumpkin was “held hostage” at the police station for up to ten-and-a-half hours. Plaintiffs claim deprivations of their civil rights under 42 U.S.C. §1983 in the form of false arrest as to both Lloyd and Lumpkin, and excessive detention as to Lumpkin alone. Defendants, for their part, argue that Plaintiffs’ arrests were supported by probable cause; Lumpkin’s detention was not excessive; and, at the very least, Defendants are entitled to qualified immunity.Pending before the Court is Defendants’ motion for summary judgment. For the reasons discussed below, the Court grants Defendants’ motion in full.BACKGROUND¹A. Factual BackgroundIn October 2013, Gett Taxi — an on-demand transportation company — reported fraudulent credit card activity to the New York City Police Department (the “NYPD”). (Def. 56.1 1). On January 9, 2014, the company provided the NYPD with two phone numbers (the “Phone Numbers”) for the accounts linked to the fraudulent charges. (Id. at