Daniel Madero v. Owen McGuinness, 97 F.4th 516

In February 2018, a hit-and-run accident in Rockford, Illinois led to a confrontation involving four participants: Madero (plaintiff), Philbee (alleged victim), and two witnesses (Daehler and Keck).
Philbee, Daehler, and Keck claimed Madero was the hit-and-run driver and that he struck Philbee in the face with a key.
Madero denied being the hit-and-run driver and claimed he acted in self-defense during the confrontation.
Officer McGuinness arrived on the scene and, crediting the three witnesses over Madero, arrested Madero for aggravated battery and issued traffic citations.
Later in the day, further investigation suggested Madero’s car had not been involved in the hit-and-run, and charges were dropped. Madero then sued McGuinness for false arrest under the Fourth and Fourteenth Amendments.
The district court granted summary judgment to McGuinness, finding he had probable cause at the time of the arrest.

Issue	Plaintiff’s Argument	Defendant’s Argument	Held
Probable Cause for Arrest	McGuinness lacked probable cause due to conflicting and later-recanted witness testimony, and lack of vehicle damage.	He reasonably relied on consistent on-scene statements from three witnesses and visible injury to Philbee.	Officer had probable cause based on available information at arrest.
Duty to Investigate Exculpatory Evidence	McGuinness ignored evidence (no vehicle damage) that should have dispelled probable cause.	Officer need not conduct exhaustive investigation, especially when exculpatory evidence wasn’t obvious.	No duty to investigate further; no obvious exculpatory evidence.
Discrepancies in Witness Testimony	Conflicting details in witnesses’ accounts should have created doubt as to probable cause.	Minor inconsistencies did not undermine overall credibility of witnesses.	Discrepancies did not negate probable cause.
Effect of Later Recantations	Later witness recantations undermine validity of initial probable cause.	Only information available at time of arrest is relevant; later changes don’t affect probable cause.	Later evidence irrelevant to probable cause at time of arrest.

Gonzalez v. City of Elgin, 578 F.3d 526 (7th Cir. 2009) (probable cause is an absolute defense to a false arrest claim)
Chelios v. Heavener, 520 F.3d 678 (7th Cir. 2008) (probable cause exists where facts would lead a reasonable person to believe a crime was committed)
Abbott v. Sangamon County, Illinois, 705 F.3d 706 (7th Cir. 2013) (summary judgment proper when facts about probable cause are undisputed)
Seiser v. City of Chicago, 762 F.3d 647 (7th Cir. 2014) (officer may rely on credible witness account even if suspect denies wrongdoing)
McBride v. Grice, 576 F.3d 703 (7th Cir. 2009) (burden to show lack of probable cause is on the plaintiff)
Michigan v. DeFillippo, 443 U.S. 31 (1979) (existence of probable cause based on facts and circumstances at time of arrest)
Braun v. Village of Palatine, 56 F.4th 542 (7th Cir. 2022) (probable cause does not depend on officer being correct; only on reasonableness at the time)