## Facts

- Arthur Wildoner, age 70, lived with his wife in a senior housing complex in Ramsey, New Jersey.
- A neighbor reported to the complex manager that Wildoner was using loud, abusive language and threatening to throw knives at his wife.
- The manager called police; two officers interviewed the neighbor and manager, and the neighbor confirmed the reported threats.
- The officers entered the Wildoners’ apartment with Mrs. Wildoner’s consent and observed a knife on the kitchen floor and a red mark on Mrs. Wildoner’s arm.
- The officers arrested Wildoner for simple assault and removed him from the apartment.
- The officers sought and obtained a temporary restraining order under the Prevention of Domestic Violence Act after Mrs. Wildoner declined to sign a domestic-violence complaint.
- A court vacated the temporary restraining order the next day after hearing only Mrs. Wildoner’s testimony; the municipal simple-assault complaint was later dismissed at the close of the State’s case.
- Wildoner sued the municipality, police department, and officers for false arrest, false imprisonment, mistreatment, and malicious prosecution under state law and 42 U.S.C. § 1983.
- The trial court dismissed the claims on defendants’ motion; the Appellate Division reversed, finding a jury question on probable cause; the Supreme Court granted review.

## Issues

1. Whether, under the totality of the circumstances, officers had probable cause to arrest for domestic violence despite the alleged victim’s denial or unwillingness to complain.
2. Whether the existence of probable cause defeats state-law and § 1983 claims premised on false arrest and false imprisonment.

## Decision

- The Supreme Court of New Jersey reversed the Appellate Division and reinstated dismissal for the municipal and officer defendants.
- The Court held the officers had probable cause to arrest based on an identified neighbor’s detailed report plus corroborating observations in the apartment.
- Because probable cause existed, the false arrest and false imprisonment claims failed as a matter of law, and the § 1983 unlawful-seizure theory could not proceed.

## Legal Principles

- Probable cause is determined under the totality of the circumstances and asks whether the facts known to the officer would warrant a reasonable person in believing an offense has been or is being committed.
- Officers may rely on information supplied by an identified citizen witness, who is generally presumed reliable, particularly when the account is specific and contemporaneous.
- In domestic-violence investigations, an alleged victim’s denial, reluctance, or recantation does not automatically negate probable cause when other credible evidence corroborates an offense.
- Probable cause is an absolute defense to state-law claims for false arrest and false imprisonment.
- For § 1983 claims alleging unconstitutional seizure based on arrest, probable cause defeats liability absent an independent constitutional violation.

## Conclusion

The court held that a domestic-violence arrest may be supported by a reliable third-party report corroborated by officers’ on-scene observations, even when the alleged victim denies abuse, and that such probable cause bars false-arrest-based state tort and § 1983 claims.


Wildoner v. Borough of Ramsey, 162 N.J. 375 (2000)