Plaintiff did not have a sufficient possessory interest in property of the University of Michigan that he’d been entrusted with. It belonged to the University who could recapture it. Hoeltzel v. Pillsbury, 2021 U.S. Dist. LEXIS 62371 (E.D. Mich. Feb. 4, 2021).
Plaintiff was arrested on a controlled delivery of a package from India with heroin in it. He was indicted in Westchester County, NY. Nine months later, he was sufficiently exonerated that the state dropped the charge. There was no judicial probable cause determination and that precluded a defense argument of collateral estoppel. The county grand jury’s indictment was presumptively probable cause which plaintiff did not overcome because there was no showing of fraud or perjury. DuBois v. City of White Plains, 2021 U.S. Dist. LEXIS 62527 (S.D. N.Y. Mar. 31, 2021).*