Full Opinion

USCA11 Case: 25-13801 Document: 20-1 Date Filed: 11/13/2026 Page: 1 of 10 NOT FOR PUBLICATION In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 25-13801 Non-Argument Calendar ____________________ DERRELL JONES, Plaintiff-Appellant, versus GTR ENTERPRISES INC, d.b.a. Thomasville Toyota, FRANKLIN R. ROLLINS, JR., CALEB LINDBERG, Defendants-Appellees, HOYT SMITH, Defendant. ____________________ Appeal from the United States District Court for the Middle District of Georgia D.C. Docket No. 7:23-cv-00087-LAG ____________________ USCA11 Case: 25-13801 Document: 20-1 Date Filed: 11/13/2026 Page: 2 of 10 2 Opinion of the Court 25-13801 Before JORDAN, BRANCH, and KIDD, Circuit Judges. PER CURIAM: At issue in this appeal is whether two officers are entitled to qualified immunity from a claim of false arrest. Derrell Jones was arrested for theft by taking after he failed to return his rental car by the agreed-upon return date. Jones alleges that the officers arrested him without probable cause in violation of the Fourth Amendment. The district court found that the officers were entitled to qualified immunity and granted summary judgment. We affirm. I. Background On April 10, 2022, Jones made an online reservation to rent a car from GTR Enterprises, which does business as Thomasville Toyota, a dealership in Thomasville, Georgia. Jones went to the dealership and signed a contract to rent a 2022 Toyota Corolla. The contract required Jones to return the car by April 15, but Jones later extended the rental period by three days to April 18. However, on April 18, Jones called the dealership and requested to extend the rental period again, this time for another week. But Jones lacked the funds to pay for a weeklong extension, so he chose instead to extend the rental period by an additional day to April 19. On April 19, Jones called the dealership to ask for a weeklong extension again. He said that he anticipated being paid soon and that he would pay for the extension once he received those funds. Jones also admitted that he had driven over a truck tire and damaged the car. The dealership declined to grant Jones any USCA11 Case: 25-13801 Document: 20-1 Date Filed: 11/13/2026 Page: 3 of 10 25-13801 Opinion of the Court 3 further extension and told him to return the car that day. Jones, who at the time was 60 miles north of Thomasville in Albany, Georgia, told the dealership that he would attempt to drop off the car later that day. When Jones stopped communicating with the dealership and it became apparent that he would not return the car by the end of the day, the dealership called the sheriff’s office and spoke to Investigator Rollins. The dealership explained that Jones was not returning its calls and had not returned a car he had rented. Rollins told the dealership that if Jones did not bring back the car by the close of business, it should call back and file a report. Jones ultimately did not return the car on April 19. The next day, April 20, the dealership called Rollins as instructed. It told him that the car’s tracking software showed the car being driven back toward Thomasville. Rollins asked the dealership to keep him informed. The dealership then filed a report with the sheriff’s office, which dispatched Deputy Lindberg to review Jones’s rental agreement. The dealership told Lindberg that Jones “said that he was out of town, but [that was] a lie.” According to the car’s software, Jones had returned to Thomasville and used the car to go to a shopping center located only 200 yards from the dealership. Later that morning, the dealership reported to the sheriff’s office that the car’s software showed it was now parked at a nearby address. Rollins, Lindberg, and another officer, Deputy Smith, went to the address, where they found the rental car parked outside USCA11 Case: 25-13801 Document: 20-1 Date Filed: 11/13/2026 Page: 4 of 10 4 Opinion of the Court 25-13801 a home. After Lindberg knocked on the front door of the home, Jones opened it, and Lindberg placed Jones under arrest. Jones was then taken to jail and charged with theft by taking. While Jones was in jail, Rollins conducted two separate interviews with him. During the second interview, Rollins told Jones that his criminal charge was being dismissed, and Jones was released Based on this series of events, Jones filed this action against the dealership, Rollins, Lindberg, and Smith, who was later dismissed from the suit. Among other claims, Jones asserted a claim under 42 U.S.C. § 1983 for false arrest against Rollins and Lindberg. See U.S. Const. amend. IV. Jones also asserted several state-law claims, including a claim for false imprisonment against all defendants. See O.C.G.A. § 16-5-41(a). Following discovery, Rollins and Lindberg moved for summary judgment, arguing that they were entitled to qualified immunity from the false arrest claim. The district court agreed, finding that Rollins and Lindberg had arguable probable cause to suspect that Jones had committed a theft by taking under Georgia law. After granting summary judgment for the officers on the false arrest claim, the district court declined to exercise supplemental jurisdiction over Jones’s remaining state claims, including the false imprisonment claim. See 28 U.S.C. § 1367(a). Jones appealed. II. Standard of Review We review a grant of summary judgment de novo. Phillips v. City of Hanceville, 184 F.4th 1267, 1270 (11th Cir. 2026). USCA11 Case: 25-13801 Document: 20-1 Date Filed: 11/13/2026 Page: 5 of 10 25-13801 Opinion of the Court 5 III. Discussion Jones challenges the district court’s finding that Rollins and Lindberg are entitled to qualified immunity from his false arrest claim. “Qualified immunity shields government officials from liability for civil damages for torts committed while performing discretionary duties unless their conduct violates a clearly established statutory or constitutional right.” Prospero v. Sullivan, 153 F.4th 1171, 1182 (11th Cir. 2025) (quotations omitted). Officers asserting a qualified-immunity defense have the burden to establish that they were performing discretionary duties. If the officers satisfy their burden, the burden then shifts to the plaintiff to show that the officers “violated the plaintiff’s statutory or constitutional right” and “that right was clearly established at the time of the defendant’s conduct.” Id. Jones does not dispute that Rollins and Lindberg were acting within their discretionary authority. So we look to whether Jones has carried his burden of establishing that Rollins and Lindberg seized him in violation of his clearly established rights. He has not. The Fourth Amendment protects “[t]he right of the people to be secure . . . against unreasonable . . . seizures.” U.S. Const. amend. IV. “An officer violates a person’s Fourth Amendment right against unreasonable seizures if he arrests that person without probable cause.” Phillips, 184 F.4th at 1271 (alterations adopted). “Probable cause is not a high bar.” Dist. of Columbia v. Wesby, 583 U.S. 48, 57 (2018) (quotations omitted). “It requires only a USCA11 Case: 25-13801 Document: 20-1 Date Filed: 11/13/2026 Page: 6 of 10 6 Opinion of the Court 25-13801 probability or substantial chance of criminal activity, not an actual showing of such activity.” Id. (quotations omitted). And to establish the defense of qualified immunity for a false arrest claim, “an officer need not have actual probable cause, but only arguable probable cause.” Garcia v. Casey, 75 F.4th 1176, 1186 (11th Cir. 2023) (quotations omitted). “An officer has arguable probable cause if ‘a reasonable officer, looking at the entire legal landscape at the time of the arrests, could have interpreted the law as permitting the arrests.’” Id. (quoting Wesby, 583 U.S. at 67 (emphasis in original)). Rollins and Lindberg had arguable probable cause to arrest Jones for theft by taking. In Georgia, “[a] person commits the offense of theft by taking when he unlawfully takes or, being in lawful possession thereof, unlawfully appropriates any property of another with the intention of depriving him of the property, regardless of the manner in which the property is taken or appropriated.” O.C.G.A. § 16-8-2. Jones failed to return the rental car to the dealership by April 19, the scheduled return date. After Jones arrived in Thomasville on April 20, he continued to use the car rather than return it to the dealership. Based on these facts, a reasonable officer could have concluded that Jones violated section 16-8-2. Jones insists that there was no arguable probable cause to arrest him because Rollins and Lindberg knew Jones told the dealership that “he was on his way” to return the car. He also argues that based on the facts that he rented the car pursuant to a written agreement, purchased insurance, asked for extensions, USCA11 Case: 25-13801 Document: 20-1 Date Filed: 11/13/2026 Page: 7 of 10 25-13801 Opinion of the Court 7 remained in contact with the dealership, said that he planned to return the car, and drove the car toward Thomasville, not away from it, no reasonable officer would have concluded that Jones intended to deprive the dealership of its property. True, Jones entered into a valid rental contract, requested permission to extend the rental period, and brought the car back to Thomasville prior to the arrest. What Jones fails to mention, however, is that he failed to return the rental car to the dealership on the agreed-upon date after the dealership declined to grant him any further extensions and asked him to return it. And even after Jones arrived back in Thomasville the next day, he drove the car to a shopping center located only 200 yards from the dealership and still did not return it. These facts were sufficient to provide Rollins and Lindberg with arguable probable cause to suspect Jones had violated section 16-8-2. Jones points to the deposition of the dealership’s fixed operations director as further evidence that no reasonable officer would have arrested him. The operations director testified that in his 14 years of experience, he had never “seen customers arrested for not returning their [rental] cars,” and that Toyota’s corporate guidelines provide that dealerships “are not to resort to law enforcement before sending [a customer who has failed to return a rental car] a certified letter.” But whether Rollins and Lindberg possessed arguable probable cause to arrest Jones does not turn on the operations director’s personal experience or Toyota’s corporate guidelines. USCA11 Case: 25-13801 Document: 20-1 Date Filed: 11/13/2026 Page: 8 of 10 8 Opinion of the Court 25-13801 “An officer lacks arguable probable cause only if the state of the law on the date of the alleged misconduct makes it obvious that the officer’s acts violated the plaintiff’s rights in the specific set of circumstances at issue.” Garcia, 75 F.4th at 1186 (alteration adopted) (quotations omitted). Given that Jones was arrested after he failed to return the rental car when he arrived back in Thomasville, it was not “obvious” that Rollins and Lindberg’s conduct violated Jones’s rights. Id. Next, Jones argues that because there were no exigent circumstances, reasonable officers would have conducted a more thorough investigation before making an arrest. We have previously explained that officers are required to conduct a reasonable investigation to establish probable cause, but they are “not required to take every conceivable step at whatever cost, to eliminate the possibility of convicting an innocent person.” Harris v. Hixon, 102 F.4th 1120, 1129 (11th Cir. 2024) (quotations omitted). The investigation that Rollins and Lindberg conducted satisfied this standard. After the dealership reported that Jones failed to return the rental car on the specified date, Rollins and Lindberg maintained consistent contact with the dealership, which reported that Jones had driven back to Thomasville but failed to return the car. The absence of any exigent circumstances does not mean that the investigation was unreasonable or that no arguable probable cause existed to arrest Jones. Jones also cites Rollins’s deposition testimony as “compelling evidence” that he lacked arguable probable cause. USCA11 Case: 25-13801 Document: 20-1 Date Filed: 11/13/2026 Page: 9 of 10 25-13801 Opinion of the Court 9 Rollins testified that when he interviewed Jones after the arrest, Rollins was “on the fence,” and he “needed to get a little bit more information in order to make a decision if [he] wanted to follow through with the arrest, take warrants out on [Jones], or . . . just release him.” According to Jones, this testimony is proof that “the information [Rollins] possessed at the time of arrest was not sufficient to support it.” Even assuming this testimony demonstrates that Rollins was uncertain about whether Jones should have been arrested, we have repeatedly explained that the standard for arguable probable cause is “an objective one and does not include an inquiry into the officer’s subjective intent or beliefs.” Grider v. City of Auburn, 618 F.3d 1240, 1257 (11th Cir. 2010). The dealership’s report that Jones was continuing to use the car after the rental period lapsed was sufficient evidence for a reasonable officer to “interpret[] the law as permitting the arrest[].” Garcia, 75 F.4th at 1186 (quoting Wesby, 583 U.S. at 68). That Rollins subjectively harbored doubts does not mean that under these circumstances an objective officer could not have found arguable probable cause. Jones’s last argument is that if we decide that Rollins and Lindberg are not entitled to qualified immunity, we should remand the case to the district court with instructions to consider the state false imprisonment claim, which the district court declined to exercise supplemental jurisdiction over. But we do not reach that conclusion, so there is no reason to remand. IV. Conclusion USCA11 Case: 25-13801 Document: 20-1 Date Filed: 11/13/2026 Page: 10 of 10 10 Opinion of the Court 25-13801 We affirm the order of the district court. AFFIRMED.