FAGG, Circuit Judge.
James E. and Rose Lowe brought suit under 42 U.S.C. § 1983 claiming that they were arrested without probable cause in violation of their civil rights. After the jury returned verdicts for the Lowes, the district court entered judgment notwithstanding the verdicts in favor of Sheriff Dwight Tosh and Sergeant Coolidge Conlee on the ground that the Lowes' underlying criminal convictions collaterally estopped them from claiming that their arrests...
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