Lisa Williamson v. Mark Curran, Jr.
714 F.3d 432
| 7th Cir. | 2013Background
- Williamson and husband were arrested for allegedly stealing Schroeder's horse Chevallo but were acquitted at trial.
- Williamson sues Deputies Sittig and Fanella under 42 U.S.C. § 1983 for false arrest and class-of-one equal protection.
- District court dismissed the claims for failure to state a claim under Rule 12(b)(6).
- Plaintiff attached investigative reports and sheriff’s documents, which the court considered in evaluating the motion to dismiss.
- The deputies arrested Williamson under a facially valid warrant; the question is whether the warrant was supported by probable cause.
- The court held the documents, including statements by Schroeder and Capuson, provided probable cause to believe Williamson was involved in theft.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether there was probable cause for arrest | Williamson lacked involvement; arrest solely due to marital status | Documents supported belief Williamson shared responsibility and possession | Probable cause supported arrest; false arrest claim failed |
| Whether the class-of-one equal protection claim survives | Arrest based on status with no rational basis | Arrest grounded in probable cause; rational basis exists | Class-of-one claim dismissed; no irrational differential treatment proven |
Key Cases Cited
- Juriss v. McGowan, 957 F.2d 345 (7th Cir. 1992) (exception to warrant-generated arrest if officers knew lack of probable cause)
- Baker v. McCollan, 443 U.S. 137 (U.S. 1979) (facially valid warrant may not shield false arrest absent probable cause)
- Malley v. Briggs, 475 U.S. 335 (U.S. 1986) (officers’ knowledge can negate probable cause when warrant originator deceived)
- Beauchamp v. City of Noblesville, Ind., 320 F.3d 733 (7th Cir. 2003) (probable cause analysis and reliance on statements of victims/witnesses)
- Geinosky v. City of Chicago, 675 F.3d 743 (7th Cir. 2012) (recognition of class-of-one equal protection claim against police conduct)
- Reynolds v. Jamison, 488 F.3d 756 (7th Cir. 2007) (officer credibility and reliance on witnesses in probable cause context)