Chandra Turner v. City of Champaign
979 F.3d 563
| 7th Cir. | 2020Background:
- Richard Turner, a homeless man with a long history of mental-health crises, was observed disoriented and repeatedly crossing streets near the University of Illinois on Nov. 16, 2016; officers decided to detain him for his safety and called for an ambulance.
- Officers pursued Turner when he ran; Officer Wilson grabbed Turner’s shoulder, Turner shoved Wilson and grabbed at another officer, and a struggle ensued.
- Officers pulled Turner to the ground, turned him prone, placed a knee on his shoulder while handcuffing him, and later used a hobble to restrain his legs because he continued to kick and resist.
- Shortly after being restrained, officers discovered Turner was not breathing; paramedics arrived within minutes, removed restraints, and transported him to the hospital where he died.
- Autopsy found death by cardiac arrhythmia linked to an underlying heart condition; no trauma or asphyxiation was observed.
- The district court granted summary judgment for defendants; the Seventh Circuit affirmed, holding the detention and restraint were lawful and Illinois state-law immunity barred tort claims.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Lawfulness of protective detention | Turner’s estate argued detention was unnecessary and officers should have monitored from a distance | Officers had probable cause to detain Turner for his safety given disorientation and street crossings | Held: Protective detention lawful; probable cause existed |
| Use of force (grounding, knee, hobble) | Estate contended force was excessive and caused death | Defendants said force was reasonable response to active resistance | Held: Use of force was objectively reasonable under Graham; not excessive |
| Failure to intervene / Monell claim | Estate argued supervisory and municipal liability for unconstitutional force/customs | Defendants argued no constitutional violation and therefore no failure-to-intervene or municipal liability | Held: No excessive force; failure-to-intervene and Monell claims fail |
| State-law tort claims | Estate alleged wrongful death, battery, IIED | Defendants invoked Illinois Tort Immunity Act §4‑102 for protective functions | Held: Section 4‑102 absolute immunity applies; state claims dismissed |
Key Cases Cited
- Graham v. Connor, 490 U.S. 386 (1989) (sets objective reasonableness test for excessive-force claims)
- Estate of Phillips v. Milwaukee, 123 F.3d 586 (7th Cir. 1997) (upheld similar officer actions against resisting mentally ill detainee)
- Fitzgerald v. Santoro, 707 F.3d 725 (7th Cir. 2013) (upheld force in protective-detention context where subject resisted)
- Bruce v. Guernsey, 777 F.3d 872 (7th Cir. 2015) (probable cause supports mental-health protective seizure)
- Smith v. Ball State University, 295 F.3d 763 (7th Cir. 2002) (reasonable officers may mistake medical unresponsiveness for resistance)
- McAllister v. Price, 615 F.3d 877 (7th Cir. 2010) (distinct where medical symptoms were obvious and force unreasonable)
- United States v. Brown, 871 F.3d 532 (7th Cir. 2017) (department policies do not define constitutional reasonableness)
- Abdullahi v. City of Madison, 423 F.3d 763 (7th Cir. 2005) (failure-to-intervene claim depends on existence of excessive-force violation)
- Mays v. Dart, 974 F.3d 810 (7th Cir. 2020) (discusses limits on reliance on departmental policies and expert testimony)
- United States v. Place, 462 U.S. 696 (1983) (recognizes that seizure authority carries the right to use some physical coercion)