Claims
Tayvin Galanakis alleges Officers Nathan Winters and Christopher Wing of the Newton Police Department arrested him without probable cause in violation of the Fourth Amendment under 42 U.S.C. § 1983, along with state-law claims against the City of Newton, Iowa. On August 28, 2022, officers stopped Galanakis for driving with his high beams on — the only stated reason for the stop, with no indication of erratic driving. During the stop, officers noted Galanakis was chewing gum and had air fresheners on his rearview mirror. They conducted field sobriety tests; Galanakis took too many steps on the walk-and-turn portion and did not count aloud during the one-leg stand, but otherwise performed the tests without issue. He asked to take a breathalyzer, which showed no trace of alcohol. Officers then read Miranda rights and asked Galanakis to submit to a drug test at the station. He initially agreed but then requested to go home, at which point he was arrested. A subsequent drug test showed no evidence of drug use. The Eighth Circuit denied the officers' interlocutory appeal for qualified immunity on April 17, 2025, holding that no objectively reasonable officer could have concluded there was a substantial chance Galanakis was intoxicated based on the totality of circumstances, and that arguable probable cause must be assessed under the totality of circumstances rather than a divide-and-conquer approach to isolated behaviors.