A recent decision from the Southern District, Wiltshire v. Williams, reiterates that acquittal of criminal charges is not inconsistent with a finding of probable cause to arrest (which, if shown, is a complete defense to a false arrest claim):
In the instant case, Plaintiff has contended that the dismissal of his criminal case precludes a finding in his federal action that there was probable cause to arrest and prosecute him. However, even though a criminal court found that there was insufficient evidence to find Plaintiff guilty of a crime beyond reasonable doubt, that in no way precludes the defendants in a civil rights action to from arguing that there existed probable cause to arrest plaintiff and prosecute him for that crime. … Moreover, the police officer defendant and the City of New York were not parties to the underlying criminal action, and therefore did not have an opportunity at the criminal stage to argue for the existence of probable cause at the time of the arrest.
Therefore, the court denied the pro se plaintiff’s request for relief for judgment dismissing his federal civil rights case.
It should be noted that there is even case law, cited by the court, standing for the proposition that a ruling in a New York state criminal proceeding that defendant’s arrest was not supported by probable cause may not prevent the police from re-litigating that question in a subsequent § 1983 action against the police arising from that arrest. Put simply, “probable cause to arrest” and “guilt beyond a reasonable doubt” are distinct concepts that must be analyzed separately.