NEW HOLLAND, Ohio — A federal appeals court has ruled in favor of a New Holland police officer who was sued by a village resident following a series of traffic stops, a vehicle search and an arrest in 2022.
The U.S. Court of Appeals for the Sixth Circuit on Friday, Aug. 7, reversed a lower court decision that had allowed Fourth Amendment and malicious prosecution claims against New Holland Police Chief William Lawless to proceed.
The case involved Cody Henderson, who moved to New Holland in 2022 with plans to establish an organic hemp farm and expand his CBD oil business.
According to the court’s decision, Henderson became suspicious of Lawless after seeing the officer’s cruiser following him while he was riding his motorcycle through town. Henderson later followed the cruiser and confronted Lawless, telling the officer he believed he was being “profiled, targeted, and harassed.”
The encounters escalated into a series of traffic stops.
Speeding stop
On Sept. 13, 2022, Lawless and Officer Darnell Pate were patrolling New Holland when they observed a black Prius approaching the village at what they believed was an excessive speed.
Pate used radar and recorded the vehicle traveling 47 mph in a 35-mph zone.
The officers stopped Henderson, who disputed that he had been speeding. He was ultimately cited for speeding, failing to wear a seat belt, failing to present his driver’s license, improper window tint and expired vehicle registration.
Henderson later argued that the traffic stop violated his constitutional rights because he had slowed down before entering the village.
The Sixth Circuit disagreed.
The court ruled that the officers had probable cause to make the traffic stop because they had observed Henderson traveling at an excessive speed and had radar confirmation that he was traveling above the posted limit.
The court noted that police officers are required to be reasonable, not perfect, and that a reasonable mistake regarding a driver’s speed does not eliminate probable cause.
“Probable cause in the end requires just that: probability, not certainty,” the court stated.
Second stop leads to arrest and vehicle search
The second major encounter occurred Sept. 22, when Lawless and Pate again saw Henderson driving the same Prius with expired registration tags.
Henderson recorded the encounter with his cellphone.
Because of the vehicle’s dark window tint, Pate asked Henderson to lower the window farther and eventually instructed him to exit the vehicle.
Lawless told Henderson that officers had previously cited him for expired registration and had also seen him driving the vehicle without updated registration on another occasion.
The officers told Henderson that he could not legally continue driving the vehicle and that it would be impounded until the registration was renewed.
Police then began an inventory search of the vehicle.
According to the court, Henderson objected to the search, yelled at officers, refused instructions to sit away from the vehicle and walked toward officers while they were conducting the search.
Police arrested Henderson for obstructing official business.
During the inventory search, officers discovered a large black tote secured with a padlock. They opened the tote and found what appeared to be large quantities of hemp, CBD and related substances.
Because officers were uncertain about the legality of the materials, they consulted a Pickaway County Sheriff’s deputy who was at the scene and contacted the county prosecutor’s office.
The materials were sent to a laboratory for testing.
Henderson was taken to the county jail on an obstruction charge, but he tested positive for COVID-19 and could not be incarcerated. He was instead released with a citation.
His vehicle and property were later returned after he renewed the registration.
The criminal charges were eventually dismissed after prosecutors determined the substances were legal forms of hemp.
Federal lawsuit
Henderson subsequently filed a federal lawsuit against Lawless, Pate and the Village of New Holland, alleging violations of his constitutional rights along with state-law claims including malicious prosecution, conversion and civil conspiracy.
Pate was dismissed from the case after his death in an unrelated incident before Henderson filed the lawsuit.
The federal district court dismissed the claims against the village and most of the claims against Lawless but allowed Henderson’s Fourth Amendment and malicious prosecution claims against Lawless to proceed.
Lawless appealed the decision, arguing he was entitled to qualified immunity.
Appeals court sides with officer
The Sixth Circuit agreed with Lawless and reversed the district court.
The three-judge panel concluded that Lawless did not violate Henderson’s Fourth Amendment rights during either traffic stop, the vehicle inventory search or the subsequent arrest.
The court determined that the vehicle was lawfully impounded because Henderson repeatedly drove it with expired registration.
The court also ruled that New Holland’s inventory policy allowed officers to conduct a complete physical inventory of the vehicle’s contents, including the locked black tote.
Henderson argued that the police department’s procedures were not followed perfectly, including a requirement to make two copies of the inventory.
The appeals court said those procedural shortcomings did not make the search unconstitutional.
“The imperative of a policy does not make each jot and tittle of it a constitutional imperative,” the court stated.
The court also rejected Henderson’s argument that police used the inventory search as a pretext to search for criminal evidence.
Arrest for obstruction upheld
The court further determined that Lawless had probable cause to arrest Henderson for obstructing official business.
According to the ruling, Henderson’s actions went beyond simply refusing to cooperate. The court cited his attempts to prevent officers from accessing the vehicle, his repeated refusal to move away from the search, his walking toward officers and his loud and confrontational behavior.
The court concluded that those actions amounted to affirmative conduct that impeded officers while they were performing what the court determined were lawful duties.
Because the court found probable cause existed for the arrest, it also rejected Henderson’s malicious prosecution claim.
The Sixth Circuit ultimately reversed the district court’s decision, ruling in favor of Officer Lawless.
The decision was issued Aug. 7, 2026, by Chief Judge Jeffrey Sutton and Judges David McKeague and John K. Bush of the Sixth Circuit.
