Tullis v City of Yonkers

Holding The court affirmed the dismissal of false arrest, false imprisonment, and malicious prosecution claims against the officers and the City because identified citizens provided sufficient information to establish probable cause. The court further held that the City could not be held vicariously liable for the officers’ actions and dismissed the negligent supervision claim as a result.

The court’s words

The existence of probable cause constitutes a complete defense to causes of action alleging false arrest and malicious prosecution

2026 NY Slip Op 05987, at the official text

A civilian defendant who merely provides information to law enforcement authorities, who are free to exercise their own independent judgment as to whether to make an arrest and file criminal charges, will not be held liable for false arrest or malicious prosecution

2026 NY Slip Op 05987, at the official text

A claim of vicarious liability cannot stand when there is no primary liability upon which such a claim of vicarious liability might rest

2026 NY Slip Op 05987, at the official text