Donald Gaddis v. Bryan J. DeMattei, 30 F.4th 625

Gaddis cut branches from neighbor Dorothy McCombs’s tree and left them in her yard; neighbors Winstead and guest Cameron Dunford observed and McCombs called police.
Officers DeMattei, Spinka, and Lannom responded; DeMattei heard accounts that Gaddis had been loud, insulting, and pounding on a neighbor’s door and decided to arrest him for disorderly conduct.
Gaddis spoke through his screen door with officers Lannom and Spinka on his porch; DeMattei told him he was under arrest and Gaddis stepped onto the porch after being told he would be charged with resisting if he stayed inside.
Gaddis sued under 42 U.S.C. § 1983 for false arrest (against officers and private neighbors), brought a Monell claim against the City, sought injunctive relief against the chief, and asserted state-law false imprisonment against McCombs, Dunford, and Winstead.
The district court granted summary judgment for all defendants except Winstead (dismissed without prejudice); on appeal the Seventh Circuit affirmed summary judgment, converted Winstead’s dismissal to one with prejudice, and resolved issues involving probable cause, seizure, coercion, and private-party procurement.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Probable cause for arrest (§1983 false arrest)	Gaddis: officers lacked probable cause; witnesses exaggerated conduct.	Officers: DeMattei had reasonable basis from witness statements and his assessment that Gaddis disturbed others.	Held: Probable cause existed; §1983 false arrest claims fail.
Whether officers’ presence on porch constituted a Fourth Amendment seizure	Gaddis: officers’ presence and aim to keep him nearby meant a reasonable person would not feel free to leave.	Officers: porch encounter was consensual; approaching a doorway and conversing is not a seizure.	Held: No seizure; interaction was consensual.
Whether officers coerced Gaddis out of his home (Payton/coercive entry) and qualified immunity	Gaddis: threat of resisting-arrest charge coerced him to exit, violating Payton and Fourth Amendment.	Officers: no coercion; even if arguable, law was not clearly established so qualified immunity applies.	Held: Court need not decide violation; officers entitled to qualified immunity because no clearly established law on coercive encouragement to exit home.
State-law false imprisonment against McCombs and Dunford	Gaddis: they exaggerated behavior to police and procured his arrest.	McCombs/Dunford: merely providing information without directing or mounting a campaign to procure arrest is insufficient.	Held: Summary judgment for McCombs and Dunford—no procurement and probable cause existed.

Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (1978) (municipal liability requires a policy or custom causing constitutional violation)
Payton v. New York, 445 U.S. 573 (1980) (warrantless, nonconsensual entry into a home to make a routine arrest violates Fourth Amendment)
United States v. Mendenhall, 446 U.S. 544 (1980) (seizure occurs when a reasonable person would not feel free to leave)
Florida v. Jardines, 569 U.S. 1 (2013) (approach to and questioning at a home’s door can be a consensual encounter)
Harlow v. Fitzgerald, 457 U.S. 800 (1982) (qualified immunity standard: protection unless official violated clearly established law)
Pearson v. Callahan, 555 U.S. 223 (2009) (qualified immunity framework allowing courts to address clearly established prong first)
Brosseau v. Haugen, 543 U.S. 194 (2004) (clearly established law must be specific to the facts)
Saucier v. Katz, 533 U.S. 194 (2001) (original two-step qualified immunity analysis)
Wilson v. Layne, 526 U.S. 603 (1999) (absence of controlling authority in jurisdiction undermines clearly established claim)
McComas v. Brickley, 673 F.3d 722 (7th Cir. 2012) (arguable probable cause can defeat false-arrest claims)
Odorizzi v. A.O. Smith Corp., 452 F.2d 229 (7th Cir. 1971) (private-party liability for procuring an arrest requires active participation beyond giving information)
United States v. Berkowitz, 927 F.2d 1376 (7th Cir. 1991) (Payton draws a firm line at the entrance to the home)