Lake County Sheriff, Appellant-Defendant v. Michael Anthony Jordan, Appellee-Plaintiff (2025)

MEMORANDUM DECISION

Case Summary

[1] In this interlocutory appeal, the Lake County Sheriff (the “Sheriff”) claims the trial court erred in denying its motion for summary judgment on Michael Anthony Jordan's false imprisonment claim. We reverse and remand.

Facts and Procedural History

[2] In May 2008, the State charged Antonio Yanders with murder, attempted murder, and battery. A warrant for Yanders’ arrest was issued the same day. Just over ten years later, in June 2018, the State moved to reissue Yanders’ warrant with known aliases, including “Michael Anthony Jordan—D.O.B. 05/04/1973.” Appellant's App. Vol. 2 at 61. The trial court granted the State's motion, and the arrest warrant was reissued.

[3] On August 21, 2020, officers of the Sheriff's department stopped Jordan for various traffic infractions. During the stop, the officers provided dispatch with Jordan's name, a descriptor—male, Black—and date of birth—May 4, 1973—to check whether Jordan had a valid driver's license. Neither Jordan nor his passenger had a valid license, so police had the vehicle towed. Jordan and the passenger were released without incident. Soon after, however, another officer of the Sheriff's department received information from the Lake County Jail that Jordan's name and date of birth were listed as an alias on Yanders’ arrest warrant. After some internal review, the Sheriff's department determined Jordan should be arrested. Later that day, officers arrested Jordan at his home without incident and took him to jail.

[4] The next day—a Saturday—a jail records employee began reviewing documents to ensure police arrested the “right people for the right charges.” Id. at 102 (Dep. Tr. at 10). The employee compared photos of Jordan and Yanders, noting they “looked different.” Id. at 103 (Dep. Tr. at 15). Concerned the wrong person was in custody, the employee emailed the assistant jail warden to discern her next steps. She was told to advise her supervisor, and they would notify the courts on Monday to get Jordan into court “as soon as they possibly could.” Id. at 104 (Dep. Tr. at 21). The employee explained “we had a court order” and so the courts “also have a say[ ] in determining if we have the correct person.” Id.; see id. at 117 (Dep. Tr. at 14–15) (the jail records supervisor explaining, “We can give our opinion ․ and then, we can forward it on up the chain, but we can't make [the] determination” of whether the jail has the right person in custody; “[i]n order to get him released, he has to go ․ in front of the judge.”).

[5] When jail records staff talked with court personnel on Monday, they were told Jordan did not go to court that morning because he had refused to undergo certain medical tests and was in quarantine. Jordan appeared in court on Friday, August 28, and the court ordered him released. The Lake County Jail did not release Jordan on this day, however, citing an active warrant for his arrest in Black Hawk County, Iowa, and a request by Black Hawk County to hold Jordan as they arranged for his extradition. On Monday, August 31, the Black Hawk County Sheriff informed the Sheriff it no longer planned to extradite Jordan. Jordan was released from the Lake County Jail later that day.

[6] In May 2021, Jordan filed an “Amended Complaint for False Imprisonment” in the Lake Superior Court, asserting Lake County and the Sheriff “negligently caused [Jordan] to be deprived of his freedom for twelve (12) days.” Id. at 31.¹ In early 2023, the Sheriff moved for summary judgment. After a hearing, the trial court denied the Sheriff's motion and certified its order for interlocutory appeal.² This Court accepted jurisdiction. See Ind. Appellate Rule 14(B).

Summary Judgment Standard of Review

[7] We review a trial court's summary judgment decision de novo, applying the same standard as the trial court. Cave Quarries, Inc. v. Warex LLC, 240 N.E.3d 681, 684 (Ind. 2024). A party seeking summary judgment must establish “the designated evidentiary matter shows that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law.” Ind. Trial Rule 56(C). “A fact is ‘material’ if its resolution would affect the outcome of the case, and an issue is ‘genuine’ if a trier of fact is required to resolve the parties’ differing accounts of the truth, or if the undisputed material facts support conflicting reasonable inferences.” Hughley v. State, 15 N.E.3d 1000, 1003 (Ind. 2014) (quoting Williams v. Tharp, 914 N.E.2d 756, 761 (Ind. 2009)).

[8] The initial burden falls on the party seeking summary judgment to “demonstrate the absence of any genuine issue of fact as to a determinative issue.” Id. (quotation omitted). When deciding whether the movant has carried this burden, we consider only the evidence designated to the trial court and draw all reasonable inferences in the non-movant's favor. Isgrig v. Trs. of Ind. Univ., 256 N.E.3d 1238, 1244 (Ind. 2025). If the movant makes this requisite showing, the burden then “shifts to the non-movant to ‘come forward with contrary evidence’ showing an issue for the trier of fact.” Hughley, 15 N.E.3d at 1003 (quoting Williams, 914 N.E.3d at 762). In doing so, the non-moving party “may not rest upon the mere allegations or denials of his pleading.” T.R. 56(E).

[9] Although summary judgment “is a desirable tool to allow the trial court to dispose of cases where only legal issues exist[,]” it is also a “blunt ․ instrument” not designed to be a “summary trial.” Hughley, 15 N.E.3d at 1003–04 (internal quotations and citations omitted). So, summary judgment “is not appropriate merely because the non-movant appears unlikely to prevail at trial.” Id. at 1004 (quotation omitted). Rather, “Indiana consciously errs on the side of letting marginal cases proceed to trial on the merits, rather than risk short-circuiting meritorious claims.” Id. (describing summary judgment as a “relatively high bar”).

The trial court erred by denying the Sheriff summary judgment.

[10] The Sheriff contends the trial court erred in denying its summary judgment motion because: (1) Jordan was lawfully arrested; and (2) the Sheriff is entitled to judicial immunity.³ Because we agree with the Sheriff that Jordan was lawfully arrested, we need not delve into immunity.

[11] False imprisonment is the unlawful restraint upon one's freedom of movement or the deprivation of one's liberty without consent. Donovan v. Hoosier Park, LLC, 84 N.E.3d 1198, 1207 (Ind. Ct. App. 2017). Apparent from those elements, the deprivation of one's liberty must be unlawful or without legal process. See Delk v. Bd. of Comm'rs of Del. Cnty., 503 N.E.2d 436, 439 (Ind. Ct. App. 1987); Stine v. Shuttle, 186 N.E.2d 168, 171 (Ind. App. 1962) (in banc) (explaining the term “false” as used in “false imprisonment” and “false arrest” is synonymous with “unlawful”); see also Wallace v. Kato, 549 U.S. 384, 388–89 (2007) (“The sort of unlawful detention remediable by the tort of false imprisonment is detention without legal process[.]”). Such deprivation may arise when an arrest or detention is made “without warrant or [with] a warrant that charges no offense[ ] or is void[,] or the person arrested is not the person named in the warrant[.] [T]he arrest in such actions must be based upon a void, erroneous or irregular process.” Stine, 186 N.E.2d at 171 (internal citations omitted); see 32 Am.Jur.2d False Imprisonment § 76 (2025) (“Imprisonment under legal authority is not false imprisonment; that is, false imprisonment claims do not lie for a detention made by virtue of legal process issued by a court or an official with jurisdiction to issue such process.”).

[12] The material fact here is whether Jordan was detained without legal process. The Sheriff designated the following evidence in support of its motion for summary judgment: the Chronological Case Summary for Yanders’ criminal case; the State's motion to reissue the arrest warrant for Yanders to include known aliases, including “Michael Anthony Jordan[,] D.O.B. 05/04/1973,” Appellant's App. Vol. 2 at 61; the court order granting the State's motion and ordering the Clerk to update the warrant to reflect Yanders’ known aliases; the court's August 28, 2020, order to release Jordan; and a letter from Black Hawk County dated August 31, 2020, telling the Sheriff it had decided not to extradite Jordan. The Sheriff also designated the deposition testimony of several Sheriff's employees: the officer who initially stopped Jordan and later arrested him; the jail records employee who first reviewed records and compared the photos of Yanders and Jordan; the jail records supervisor; and the booking officer who interacted with Black Hawk County after the trial court ordered Jordan's release.

[13] With this evidence, the Sheriff negated an element of Jordan's false imprisonment claim by showing that Jordan was not unlawfully restrained, as he was arrested pursuant to a facially valid warrant. The burden then shifted to Jordan to designate evidence showing there was a genuine issue of material fact precluding summary judgment. He did not do so.

[14] In Jordan's response to the Sheriff's motion for summary judgment, he did not disagree with any of the “undisputed material facts” the Sheriff set forth in its motion, including that the Sheriff “received information from the jail that Michael Jordan, DOB May 4, 1973, was a known alias for Antonio Yanders who [was] wanted on a murder warrant” and that after consultation, officers “made the determination that Jordan should be arrested” because he “was believed to be Yanders.” Id. at 46–47 (Sheriff's Memorandum in Support of Motion for Summary Judgment); see id. at 143 (Jordan's response to Motion for Summary Judgment setting forth only procedural facts primarily about Lake County's inclusion and ultimate dismissal as a defendant). Jordan's designated evidence consisted of his amended complaint ⁴ and the curriculum vitae and affidavit of Dennis Waller, an expert in issues “related to police policy, procedure and practice.” Id. at 159. In Waller's opinion, “[a]fter it was factually determined that Mr. Jordan was not Antonio Yanders ․, he should have been released immediately.” Id. at 164. But all opinions in Waller's affidavit are based on events that occurred after Jordan's arrest; Jordan did not designate any evidence showing the legal process leading to his detention was unlawful or invalid.

[15] Jordan now argues on appeal that whether the officers acted in good faith when they arrested him is a question of fact. But a facially valid arrest warrant is grounds for a good faith, reasonable belief that there was probable cause to make an arrest. Conwell v. Beatty, 667 N.E.2d 768, 775 (Ind. Ct. App. 1996). Even drawing all reasonable inferences in Jordan's favor, the arrest warrant here provided the Sheriff with a reasonable belief that there was probable cause to arrest Jordan. The full name and date of birth of an alias identified on the warrant matched Jordan's full name and date of birth, and Waller stated in his affidavit that “[a]n alias may be used as a basis for probable cause[.]” Appellant's App. Vol. 2 at 165; cf. Brown v. Patterson, 823 F.2d 167, 169 (7th Cir. 1987) (affirming dismissal of plaintiff's Section 1983 suit for failure to state a claim of unlawful arrest when officer arrested man whose name was the same as an alias used by the target of a valid warrant), cert. denied. Discrepancies in the height and weight descriptors and the nine-year difference in Yanders’ and Jordan's dates of birth were not known until after Jordan was arrested and were uncovered by jail staff after he was booked, not by the arresting officers.

[16] To the extent Jordan bases his claim on the Sheriff continuing to hold him after questions arose about whether he was Yanders, he makes several bald assertions without citation to evidence or authority. For instance, he claims the Sheriff “was not required to get a court order when the wrong person had been arrested under the warrant.” Appellee's Br. at 5. But the Sheriff's designated evidence shows otherwise. Two jail records employees stated they could not determine for themselves whether Jordan was the wrong person; they could only give their opinion and bring the issue to the court because they were holding him on a warrant naming him. Jordan also claims the warrant “does not justify the detention of Jordan after fingerprints established he was not Yanders.” Id. at 8. Even assuming this is true, there is no designated evidence establishing the date on which the fingerprints were compared and determined to not match.

[17] Finally, Jordan “cannot take advantage of delays due to his or her own conduct[.]” Grooms v. Fervida, 396 N.E.2d 405, 412 (Ind. Ct. App. 1979). He was not taken before the court at the earliest opportunity because he refused to take required medical tests and was placed in quarantine. And he was not released on the day the court entered its order because there was an out-of-state warrant for him.

[18] Jordan's arrest and detention was obviously unfortunate, but it was not unlawful. The Sheriff designated evidence showing Jordan's arrest and imprisonment were under legal authority, negating an element of Jordan's false imprisonment claim, and Jordan did not come forward with evidence showing a genuine issue as to that material fact. The trial court should have granted the Sheriff's motion for summary judgment.

Conclusion

[19] We reverse and remand with instructions for the trial court to grant summary judgment to the Sheriff.

[20] Reversed and remanded.

FOOTNOTES

1.   Jordan's original complaint named only Lake County as a defendant. Jordan subsequently sought and was granted leave to amend his complaint to add the Sheriff. Eventually, the trial court granted Lake County's motion for judgment on the pleadings and dismissed the county as a defendant.

2.   The Sheriff did not request in its Notice of Appeal that a transcript of the summary judgment hearing be prepared.

3.   The Sheriff couches its arguments in terms of whether the trial court erred in “holding” certain things. See Appellant's Br. at 4 (stating the first issue as “[w]hether the Trial Court incorrectly held that an arrest pursuant to a facially valid arrest warrant was not a lawful arrest”). The trial court's order, however, is one line, issued the same day as the hearing: “[T]he Court denies the [Sheriff's] Motion for Summary Judgment.” Appellant's App. Vol. 2 at 184. As noted above, the Sheriff did not request a transcript of the summary judgment hearing, so if the trial court explained its decision during the hearing, we are not privy to the explanation. Regardless, findings of fact and conclusions thereon are neither required nor prohibited in a summary judgment ruling, Smith v. Delta Tau Delta, Inc., 9 N.E.3d 154, 157 (Ind. 2014), and if made, they are not binding on this Court, Glob. Caravan Techs., Inc. v. Cincinnati Ins. Co., 135 N.E.3d 584, 588 (Ind. Ct. App. 2019), trans. denied.

4.   He also designated his original complaint against Lake County and the trial court's order dismissing the county as a defendant.

Kenworthy, Judge.

Judges Foley and Scheele concur. Foley, J., and Scheele, J., concur.