Fourth Circuit clarifies 12(b)(6) standard in a wrongful-arrest case

Goines v. Valley Cmty. Servs. Bd., No. 15-1589 (4th Cir. May 9, 2016).

Gordon Goines has cerebellar ataxia, which affects his coordination and speech but not his intellect. A cable technician came to check out some connection problems that Gaines had reported, and determined that somebody had spliced—that is, stolen—the cable going to Gaines’s home. The technician told Goines to report the theft to the police. 

And that’s just what Goines did. According to Goines, he told the police that his TV was making noises because a neighbor had stolen his cable. The police, without turning on the TV, concluded that Goines was hearing voices, and, over his protests, took him into custody. There he was strip-searched and handcuffed to a table. He was eventually released.

Goines sued the arresting officers for taking him into custody without probable cause for believing he was mentally ill and a danger to himself or others. The district court granted the police officers’ Rule 12(b)(6) motion to dismiss Goines’s complaint.

The question on appeal is whether the district court should have considered a rather partisan document—the arresting officers’ report—in quite the way that it did. Normally courts considering motions to dismiss can consider a document outside the complaint only if it’s integral to the complaint and its authenticity isn’t questioned. Thus, for example, a court can normally consider the text of a contract in a breach-of-contract action, even if the contract isn’t attached to the complaint. In these circumstances, if the outside document contradicts the complaint—if, say, a contract provides for the sale of X widgets while the breach-of-contract complaint alleges it provided for Y—the outside document trumps the complaint. Here, the district court treated the police officers' report in more or less this way.

As the Fourth Circuit notes, though, the outside-document-governs rule can’t possibly be the rule for all outside documents. If it were, a libel case couldn’t possibly get off the ground: the libelous statement in an outside document would then trump a complaint’s denial of the libel’s truth. So the general rule must be that the outside document trumps the complaint if a complaint relies on an outside document for the truth of its contents.

Here, though, Goines wasn’t relying on the arresting officers’ report for the truth of its contents. In fact, he relied on it at times for nearly the opposite purpose: to show that what he told the police officers, and then what the police officers reported, were worlds apart. Goines relied on the report to show that the police officers ignored what he told them, and for that reason lacked probable cause to arrest him. 

When Goines’s allegations themselves are taken as true, the Fourth Circuit holds, they state a valid claim against the arresting officers. The district court’s dismissal of that claim is reversed.