2634 REVIEW DENIED Although a plaintiff suing public officials for false arrest action can recover damages resulting from post-arraignment conduct, s/he can recover damages for physical and emotional suffering caused by pre-arraignment incarceration, even if that suffering occurs after the arraignment; in an action for false arrest under the Civil Rights Act (42 USC 1983), plaintiff may be entitled to damages for incarceration that occurred after the filing of a criminal complaint, if s/he can show that the filing did not result from an exercise of independent judgment by the prosecutor.CitationVALENTIN v SUPERIOR COURT (False Arrest Damages) 78 CA4 212 [See: Gill v Epstein 62 C2 611; Jackson v City 121 CA3 579; Asgari v City 15 C4 744, T/AT 7/97; Pool v City 42 C3 1051; 42 USC 1983; Smiddy v Varney 665 F2 261]
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