Reuben Jelani Adams, et al. v. Lexington-Dayette Urban County Government, et al.

Lexington, Kentucky, personal injury lawyer represented the Plaintiffs on civil rights violation theories.



Plaintiffs are five football players at the University of Kentucky ("UK”) who were subject to racial taunts and physical violence at a fraternity-sponsored party. Yet after the altercation, defendant Detective Cory Vinlove, a Lexington police officer, initiated criminal charges against plaintiffs. A grand jury eventually refused to indict plaintiffs but, by then, news of the investigation had already hurt plaintiffs' reputations and careers.



After being cleared of wrongdoing, plaintiffs sued Vinlove, Sergeant Donnell Gordon, Lexington Police Chief Lawrence Weathers, and Lexington-Fayette County Urban Government ("LFCUG”), asserting various federal and state-law claims. Defendants moved to dismiss all claims except a state malicious prosecution claim.



A Fourth Amendment malicious prosecution claim consists of four elements. Sykes v. Anderson, 625 F.3d 294, 308–09 (6th Cir. 2010). First, the plaintiff must prove that "a criminal prosecution was initiated against him and that the defendant 'made, influenced, or participated in the decision to prosecute.'” Wright v. City of Euclid, 962 F.3d 852, 875 (6th Cir. 2020) (quoting Sykes, 625 F.3d at 308)). Second, there must be "a lack of probable cause for the criminal prosecution.” Id. Third, "as a consequence of a legal proceeding,” plaintiff must have "suffered a deprivation of liberty apart from the initial seizure.” Id. at 875–76. And fourth, the criminal proceeding must have been resolved in his favor. Id. at 876.

The district court granted the motion, reasoning that as damaging as defendants’ actions were, they were not deprivations of liberty under the Fourth Amendment as required for the federal claims. The district court also dismissed plaintiffs’ state-law claims, finding that the alleged facts failed to state a claim under state law. We now affirm the district court.