There is no such thing as a negligent search and seizure claim. Rudd v. City of Jonesboro, 2017 U.S. Dist. LEXIS 28682 (E.D.Ark. March 1, 2017).
The search of plaintiff’s truck in a garage was reasonable and officers get qualified immunity for the search by consent and under a search warrant except for the contents of an envelope. The garage owner noticed a missing VIN plate and asked plaintiff about it, and plaintiff surreptitiously placed another on the vehicle when the garage owner wasn’t looking. Then he told the police. The supplemental state claims were arbitrarily dismissed. Partially remanded. Patel v. Hall, 2017 U.S. App. LEXIS 3738 (10th Cir. March 1, 2017).*