艾杰诉麦凯布等案

On June 10, 2019, Roland Edger, a mechanic in Huntsville, Alabama, was repairing a customer's car in a church parking lot with his stepson. A security guard called 911, and Officer Krista McCabe arrived, demanding Edger produce a driver's license or ID. Edger refused, explaining he was fixing a car. Officer Cameron Perillat arrived and handcuffed Edger, arresting him for obstructing governmental operations. The charges were later dropped. Edger filed a § 1983 civil rights lawsuit alleging false arrest in violation of the Fourth Amendment. The district court initially granted qualified immunity to the officers, but the Eleventh Circuit reversed in 2023, holding that officers lacked probable cause. After a two-day jury trial in October 2024, Judge Liles Burke ruled the officers falsely arrested Edger, with the jury awarding $77,000 in damages.

On October 30, 2024, a federal jury awarded Roland Edger $75,000 in compensatory damages and $2,000 in punitive damages ($1,000 against each officer), totaling $77,000. Judge Liles Burke ruled that the officers falsely arrested Edger and held the City of Huntsville liable as the officers' employer. Attorney's fees were to be awarded at a later date. The Eleventh Circuit had previously reversed the district court's grant of qualified immunity, holding that Alabama law clearly established that officers cannot demand physical identification beyond name, address, and explanation of actions.

Whether Officers McCabe and Perillat had probable cause to arrest Edger for refusing to produce physical identification. Central legal questions included: (1) whether Alabama Code § 15-5-30 requires a person to produce a physical ID or merely provide name, address, and explanation of actions; (2) whether the officers were entitled to qualified immunity; and (3) whether the arrest violated Edger's Fourth Amendment rights against unreasonable seizures.

The case reinforced that under Alabama law, citizens are only required to provide name, address, and an explanation of actions—not physical ID—during non-traffic stops. It served as a precedent limiting qualified immunity in false arrest cases. The City of Huntsville committed to incorporating additional training to align practices with the court's ruling. Edger's attorney stated the verdict would lead to better police practices, and the case was cited in subsequent civil rights litigation challenging unlawful ID demands.