Campbell v. City of San Antonio

What This Case Is About

Campbell v. City of San Antonio is a case about mistaken identity and the limits of § 1983 liability when police arrest the wrong person. Gloria Campbell was arrested for selling crack cocaine — a crime actually committed by a woman named Gloria Smothers. Despite Campbell’s innocence, the Fifth Circuit found that the detective had probable cause for the arrest based on the identification procedures he followed, and dismissed the case.

The Facts

On April 13, 1990, Detective George Vidal of the San Antonio Police Department purchased a small amount of crack cocaine from a woman who identified herself as Gloria Smothers. In August 1990, using SAPD identification equipment and procedures, Vidal concluded that Gloria Smothers was actually plaintiff Gloria Jean Campbell, whose maiden name was Smotherman.

On September 4, 1990, Vidal identified Campbell as Gloria Smothers in a photographic lineup using Campbell’s Texas driver’s license photograph. Based on this identification, Campbell was arrested and charged with delivery of a controlled substance.

Campbell was innocent — she was not the woman who sold Vidal the drugs. She filed suit under § 1983 against Vidal and the City of San Antonio, alleging false arrest, malicious prosecution, and related constitutional violations.

What the Court Decided

The Fifth Circuit affirmed the dismissal of all claims.

On the false arrest claim, the court held that Detective Vidal had probable cause to arrest Campbell. Probable cause does not require certainty — it requires only a reasonable belief, based on the totality of circumstances, that the suspect committed a crime. Vidal used standard police identification procedures to match the drug seller to Campbell. While the identification turned out to be wrong, the procedures he followed were reasonable, and reasonable mistakes do not negate probable cause.

The court found Vidal was entitled to qualified immunity because his actions were objectively reasonable. An officer who makes an honest mistake in identification, using accepted procedures, does not violate clearly established law.

On the municipal liability claim against the City, the court applied Monell and found that Campbell failed to identify any official policy or custom that caused her arrest. The identification procedures Vidal used were standard SAPD practices, and Campbell did not show they were constitutionally deficient.

Why This Case Matters for Your § 1983 Case

Campbell v. City of San Antonio teaches several important lessons:

• Probable cause covers honest mistakes. Officers do not need to be correct — they need to be reasonable. If an officer follows standard identification procedures and reaches a wrong conclusion, the arrest may still be supported by probable cause.

• Qualified immunity protects reasonable errors. The qualified immunity doctrine is specifically designed to protect officers who make reasonable mistakes. Only when an officer’s conduct is clearly unreasonable in light of established law will qualified immunity be denied.

• Innocence does not equal a constitutional violation. The fact that a plaintiff is actually innocent does not mean the arrest violated the Constitution. The Fourth Amendment asks whether the officer’s belief was reasonable at the time, not whether it was ultimately correct.

• Municipal liability requires a deficient policy. To hold a city liable, you must show that the city’s policies or customs were the “moving force” behind the violation. Standard identification procedures, even if imperfect, generally do not constitute an unconstitutional policy.

Key Takeaway

Being arrested for a crime you did not commit is a terrible experience, but it does not automatically give rise to a § 1983 claim. Campbell v. City of San Antonio holds that if officers followed reasonable procedures and had an objectively reasonable basis for the arrest, both the officers and the city will be shielded from liability — even when the plaintiff turns out to be completely innocent.