Eric Hudson v. Ronald Salier
676 F. App'x 587
| 7th Cir. | 2017Background
- Eric Hudson was a passenger stopped for a broken headlight; officer Ronald Salier arrested driver Johnny Hicks on a warrant and then checked Hudson’s license to allow the car to be driven away.
- The squad-car computer returned a warrant for “Clifton Hudson” (Eric’s brother) for a ticket on an uninsured vehicle; the entry showed Clifton’s physical descriptors, Clifton’s name as an alias for Eric, and a birthdate matching Eric’s.
- Salier arrested Eric based on the computer hit and transported him to jail for fingerprinting; family members at the scene protested that Eric was not the subject of the warrant but Salier proceeded anyway.
- Jail staff booked Eric after fingerprinting failed to identify the mismatch; a family member later bonded him out after several hours in custody.
- Eric sued under 42 U.S.C. § 1983 claiming false arrest in violation of the Fourth and Fourteenth Amendments; the district court granted summary judgment to Salier, concluding the arrest was reasonable.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether arrest was reasonable where officer may have mistaken arrestee for warrant target | Hudson: arrest unreasonable because officer admitted only a “50/50” chance and license indicated possible mismatch | Salier: arrest reasonable because computer match (alias + birthdate) and physical descriptors gave probable cause | Court: reasonable — match of identifying info and physical description sufficed |
| Whether officer had duty to investigate contrary evidence (family protests, license) before arrest | Hudson: officer should have further investigated given ambiguity | Salier: not required to seek exculpatory evidence once probable cause existed | Court: no duty to investigate further; probable cause justified arrest |
Key Cases Cited
- Hill v. California, 401 U.S. 797 (police may lawfully arrest a person they reasonably believe matches warrant target)
- Catlin v. City of Wheaton, 574 F.3d 361 (7th Cir. 2009) (arrest reasonable where arrestee’s characteristics sufficiently matched target)
- Tibbs v. City of Chicago, 469 F.3d 661 (7th Cir. 2006) (reasonable belief standard tolerates probabilities short of certainty)
- Baker v. McCollan, 443 U.S. 137 (officer not required to search for evidence negating probable cause)
- Atkins v. City of Chicago, 631 F.3d 823 (7th Cir. 2011) (same principle applied at summary judgment)
AFFIRMED.