## Facts

- John Wright went to a Bozeman driver’s-license office to renew his Montana driver’s license, which required completing an application, passing a written exam, and taking a driving test.
- Although Montana law no longer required a Social Security number on the application, an employee still requested Wright’s Social Security number.
- Wright refused to provide his Social Security number, and the employee assigned him a random number for processing the application.
- Later the same day, Wright returned to take the driving test and presented proof of insurance.
- Ray Houghton, the driving examiner, rejected Wright’s proof of insurance and refused to administer the driving test.
- Wright argued with Houghton, and Houghton told Wright to leave and not return that day.
- Wright returned to the office later that day; upon seeing Wright return, Houghton called the police without first speaking to or interacting with Wright.
- An officer arrived and told Wright to leave the premises; Wright refused.
- Wright was arrested for disorderly conduct and criminal trespass.
- Wright was released on bail, and the charges against him were later dismissed.
- A few days later, Wright returned to the licensing office, presented proof of insurance acceptable to the examiner, took the driving test, and received a renewed driver’s license.
- Wright sued Houghton, the State of Montana, the City of Bozeman, and a Bozeman police officer for false arrest.
- Defendants moved for summary judgment; Wright submitted no affidavits or other evidence opposing the motion.
- The trial court granted summary judgment for defendants, and Wright appealed.

## Issues

1. Whether summary judgment was proper on Wright’s false-arrest claim when Wright submitted no evidentiary material opposing defendants’ showing that the arrest was supported by probable cause.
2. Whether probable cause could be resolved as a matter of law on summary judgment where the nonmoving party failed to create a genuine dispute about the facts known to the arresting officer at the time of arrest.

## Decision

- The Montana Supreme Court affirmed the district court’s grant of summary judgment for the defendants.
- The court held that Wright failed to meet his burden to present evidence showing a genuine issue of material fact in response to the motion for summary judgment.
- On the record presented, the court treated defendants’ factual showing as undisputed and concluded that probable cause defeated the false-arrest claim.
- The later dismissal of the criminal charges did not, by itself, establish that the arrest lacked probable cause when made.

## Legal Principles

- Probable cause is a complete defense to a civil claim for false arrest/false imprisonment.
- On summary judgment, once the moving party makes a supported showing that no genuine issue of material fact exists, the opposing party must respond with admissible evidence (such as affidavits or other materials); allegations or argument in pleadings are not enough.
- When the material historical facts about what the officer knew and what occurred are not genuinely disputed, the court may decide probable cause as a matter of law on summary judgment.
- Probable cause is evaluated based on the facts and circumstances known at the time of the arrest, not the eventual outcome of the criminal case.

## Conclusion

The Montana Supreme Court affirmed summary judgment for the State and the other defendants because Wright offered no evidence to dispute defendants’ showing that officers had probable cause to arrest him after he returned to the driver’s-license office and refused a police order to leave; the later dismissal of the criminal charges did not change the probable-cause analysis.


Wright v. State, 752 P.2d 748 (1988)