v. New York, 392 U.S. 40, 66-67, 88 S.Ct. 1889, 20 L.Ed.2d 917 (1968) (“[D]eliberately furtive actions and flight at the approach of strangers or law officers are strong indicia of mens rea, and when coupled with specific knowledge on the part of the officer relating the suspect to the evidence of crime, they are proper factors to be considered in the decision to make an arrest.”); United States v. McCarty, 862 F.2d 143, 147 (7th Cir.1988) (concluding that there was “probable cause to believe that [defendant] was a convicted felon who possessed a firearm” and observing that “his furtive gesture when he was stopped, reinforced the reasonableness of the officers’ belief that [he] had committed or was committing a crime”); United States v. Sanders, 631 F.2d 1309, 1312 (8th Cir.1980) (<HOLDING>); see also 2 Wayne R. LaFave, Search and
holding that there is no  1983 cause of action for false arrest unless the arresting officer lacked probable cause holding that under fourth amendment standards for determining probable cause for arrest and probable cause for search and seizure are same holding that there was probable cause to arrest defendant and that defendants furtive movement and his contemporaneous facial expression provided support for that result holding that there was no probable cause to arrest the plaintiff because the facts of the case amounted to a contract dispute holding that probable cause is a complete defense to an action for false arrest