Judge refuses to toss $500,000 jury verdict against Denver officer over wrongful arrest at DIA

A federal judge upheld a jury’s $500,000 verdict and finding of liability against a Denver police officer whose faulty probable cause statement led to the wrongful arrest of a man at Denver International Airport.

After a jury earlier this year determined Officer Karl Coleman acted maliciously when he erroneously wrote on legal paperwork that Juan Valenzuela was using a forged California identification card to board a flight, Coleman moved to overturn the judgment against him. In the alternative, he asked for a reduction in the amount of the jury’s award or a new trial.

U.S. District Court Senior Judge Christine M. Arguello, who presided over the civil trial, rejected Coleman’s request on July 7. She found the jury could easily have concluded Coleman knew of information at the time suggesting Valenzuela was not guilty of forgery, yet failed to include it in his probable cause statement.

“Defendant acknowledged that plaintiff provided several corroborating forms of identification that matched the biographical information and picture on plaintiff’s California ID card, including multiple work ID badges from the correctional facility where he was employed, firearm certificates, transport certificates, other photographs, debit cards, a social security card, and a plane ticket,” Arguello wrote in her order.

Coleman, she added, had “obvious” reasons to doubt Valenzuela forged his identification, but mentioned none of them when describing the alleged crime.

Valenzuela approached a security checkpoint at DIA just before 6 a.m. on Feb. 15, 2017. He did not have his current California driver license in his possession, so he showed an expired ID card. Although the ID correctly displayed his photo and information, it was visibly warped, cracked and otherwise damaged.

Airport security personnel examined the card and quizzed Valenzuela about why it was damaged. They handed it to Denver police officers at the airport, who suspected it might be fraudulent.

Police handcuffed and detained Valenzuela while seeking further verification. They called his employer — the Crowley County Correctional Facility, where Valenzuela was a corrections officer — who confirmed Valenzuela worked there.

Coleman, meanwhile, contacted the National Crime Information Center and determined Valenzuela had a valid California license with the same identification number as the expired license. Although California’s practice is to give a unique ID number to each person, Coleman still was suspicious of Valenzuela.

Police eventually decided to charge Valenzuela with felony forgery. Under Colorado law, the offense requires the falsification or alteration of a written government document with an intent to defraud.

Coleman’s probable cause statement amounted to two short paragraphs, claiming Valenzuela “did knowingly and willfully” commit forgery by attempting to access the concourse using a forged California ID card.

“The above statement is true and believable based on the personal knowledge and observations” of the other Denver police and DIA security officers who examined the card, Coleman added without elaboration.

Valenzuela spent two days in Denver jail, after which a state judge found probable cause of a crime existed based on the contents of Coleman’s statement. Because of the pending charges, the prison where Valenzuela worked fired him, and he lost approximately $14,000 in wages and benefits.

By May 24, 2017, the Denver District Attorney’s Office requested the forgery charge be dismissed.

Valenzuela filed a lawsuit in federal court claiming unlawful arrest, malicious prosecution and a failure by Denver to train its officers. Although Valenzuela named several defendants, a judge found most of the officers and Denver could not be held liable. However, the case against Coleman could proceed to trial based on Coleman’s lack of evidence that Valenzuela’s had intended to use his expired ID to misrepresent his identity — a key element of forgery.

“The fact that the trial court accepted Officer Coleman’s conclusory statement and found probable cause to exist to detain Mr. Valenzuela does not insulate Officer Coleman from liability for having tendered a patently-deficient probable cause statement,” wrote U.S. District Court Senior Judge Marcia S. Krieger in October 2020.

Although Coleman attempted to assert qualified immunity as a shield from civil liability, saying no prior court case had ever put him on notice that his behavior was unconstitutional, Krieger decided Coleman’s conduct was “so fundamentally inconsistent” with the constitutional requirement for probable cause that the absence of similar cases was irrelevant.

During a jury trial in early 2022, Arguello instructed jurors there was no legal dispute over whether Coleman’s actions prompted the criminal case against Valenzuela or that Coleman’s statement in support of Valenzuela’s arrest lacked probable cause. The only issues for the jury to decide were whether Valenzuela sustained damages and whether Coleman acted with malice — meaning a knowing or reckless disregard for Valenzuela’s rights.

If Coleman “purposely disregarded the high probability that his actions would deprive Mr. Valenzuela of his rights,” Arguello elaborated, “then the malice element would be satisfied.”

The jury sided with Valenzuela and awarded him $200,000 in damages caused directly by the malicious prosecution, plus $300,000 in punitive damages.

After the trial, Coleman asked Arguello to rule that, as a matter of law, he could not be found liable.

“Coleman did not include false information or omit exculpatory facts, and he testified that when he wrote it, he wholeheartedly believed the ID card was fake or forged,” wrote Jonathan Cooper with the Denver City Attorney’s Office. Cooper added Coleman had believed a detective would review his probable cause statement and his conduct, at most, was negligent instead of malicious.

Valenzuela’s attorney pushed back on that narrative, reminding Arguello the jury had seen three other probable cause statements for forgery Coleman authored during his career that were similarly short and lacking in evidence. Coleman testified at trial he has “been writing them that way for 30 years.”

“Coleman worked for almost 30 years in a position of trust that afforded him great power and responsibility when he filled out key charging documents like the PC Statement at issue. It is virtually impossible for him not to have known about his responsibilities from his experience alone, without consideration of the vast quantity of resources, training, and policies that additionally informed him,” wrote attorney Raymond K. Bryant.

Arguello, in deciding whether to toss the jury’s verdict, noted that while Coleman’s failure to further investigate the alleged forgery would not amount to malice, Coleman had actually agreed at trial that Valenzuela’s ID contained the security features he was used to seeing in identification cards. Coupled with the other identification documents Valenzuela showed officers at the time, Coleman had “obvious” reasons to doubt the ID was forged.

She also declined to overturn the jury’s award of $300,000 in punitive damages, which are in response to a defendant’s “evil motive or intent,” or if the defendant shows reckless disregard for a person’s rights. Arguello believed Coleman’s handling of the probable cause statement demonstrated recklessness.

“Plaintiff suffered emotional pain and fear as a result of his detention and four-month prosecution: He testified that he has not flown and will not fly again, he fears the police, he lost faith in the justice system, and he suffered significant emotional harm from losing his job and his family being separated because he could not provide for his children,” she wrote.

Although Coleman again asserted he was entitled to qualified immunity, Arguello dismissed that claim and agreed with Krieger’s original decision from 2020 that Coleman was not immune. Arguello determined Valenzuela was entitled to more than $485,000 in attorney fees.

An appeal in the case is pending before the U.S. Court of Appeals for the 10th Circuit.

The case is Valenzuela v. Coleman.


PREV

PREVIOUS

10th Circuit rebuffs Rocky Flats-skeptic groups' challenge to refuge trail system

The federal appeals court based in Denver has agreed the government did not violate the law when it approved a set of trail modifications at the Rocky Flats National Wildlife Refuge in 2018 without a more rigorous environmental review. In reaching its decision, a three-judge panel for the U.S. Court of Appeals for the 10th […]

NEXT

NEXT UP

Judge rejects inmate's request to order changes to prison dental policies

A federal judge has rebuffed an inmate’s request to order prison officials to halt their alleged unofficial policy of denying dental crowns to detainees, believing the Federal Bureau of Prisons should be left to manage its own medical protocols. Peter George Noe, who is incarcerated at the U.S. Penitentiary — Administrative Maximum facility in Florence, filed […]


Welcome Back.

Streak: 9 days i

Stories you've missed since your last login:

Stories you've saved for later:

Recommended stories based on your interests:

Edit my interests