Cannaday v. Sandoval, 458 F. App'x 563

Cannaday was arrested near his home in December 2004 with six grams of crack on him; police later obtained a search warrant and found large quantities of cocaine in his residence.
Wisconsin state court suppressed the residence evidence, and the state dismissed the charge; Cannaday later pled guilty in federal court to possession with intent to distribute the crack found on his person.
Cannaday sued the arresting/officer defendants under 42 U.S.C. § 1983, arguing unlawful entry without a warrant and lack of probable cause for the subsequent warrant.
The district court held the Wisconsin suppression ruling non-preclusive and granted summary judgment on qualified immunity, noting officers relied on a facially valid warrant.
On appeal, the Seventh Circuit held the state ruling did not preclude the § 1983 defense and that qualified immunity could shield officers for both entry and search given exigent circumstances and reliance on the warrant.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Preclusion of defense by state ruling	Cannaday argues Wisconsin suppression ruling precludes federal defense.	Officers contend 28 U.S.C. § 1738 and state-law doctrines do not bind federal claims here.	Not precluded; Wisconsin ruling does not control the federal § 1983 defense.
Qualified immunity for initial entry without a warrant	Cannaday contends entry without probable cause was unlawful.	Exigent circumstances justified a warrantless entry; good-faith reliance on later warrant supports immunity.	Qualified immunity applies to the initial entry due to exigent circumstances and reasonable belief in risk of evidence destruction.
Qualified immunity for the search warrant and probable cause	State court lacked probable cause; warrant was not supported by probable cause under federal law.	Warrant application relies on information and past experience; not plainly deficient; good-faith exception applies.	Qualified immunity shields officers; the warrant was not so lacking as to render belief unreasonable; record does not show personal liability.
Extent of evidence destruction risk and exigency	Officers had no reasonable belief of imminent destruction since surveillance showed no intruder.	Possible occupants could destroy evidence; knock-and-listen supports ongoing risk.	Exigent circumstances supported reasonable belief of risk; district court factual finding sustained.

Malley v. Briggs, 475 U.S. 335 (1986) (probable-cause standard for qualified immunity)
Junkert v. Massey, 610 F.3d 364 (7th Cir.2010) (warrant validity and reasonableness in immunity analysis)
United States v. Dismuke, 593 F.3d 582 (7th Cir.2010) (assessing sufficiency of probable cause in warrants)
Brooks v. City of Aurora, 653 F.3d 478 (7th Cir.2011) (reasonableness of warrant application under good-faith doctrine)
Leaf v. Shelnutt, 400 F.3d 1070 (7th Cir.2005) (exigent-circumstances exceptions to warrants)
Kentucky v. King, 563 U.S. 452 (2011) (police may enter without a warrant if exigent circumstances exist)
Allen v. McCurry, 449 U.S. 90 (1980) (preclusion in federal courts under 28 U.S.C. § 1738)
Michelle T. v. Crozier, 173 Wis.2d 681 (1993) (offensive collateral estoppel in Wisconsin)