DUNCAN, J.
Plaintiff brought a civil action against Washington County Deputy Sheriff Henningsen and Washington County, asserting that Henningsen had arrested her without probable cause. Plaintiff's claim against defendant Henningsen, brought pursuant to 42 U.S.C. section 1983, was that he violated her Fourth Amendment right to be free from unreasonable seizures. Plaintiff's claim against defendant Washington County was for the tort of false arrest.
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