Smith v. First State Animal Center & Spca

Summary

The Supreme Court of Delaware affirmed summary judgment for the SPCA and its employees on Smith's false-arrest, malicious-prosecution, and constitutional claims. It held that the SPCA officer had authority and probable cause to obtain the arrest warrant, that Smith lacked evidence of actual malice, that the individual defendants were protected by qualified immunity on the authority theory, and that the claims against the SPCA failed under municipal-liability principles.