Matthews v. City of East St. Louis
2012 U.S. App. LEXIS 6206
| 7th Cir. | 2012Background
- Matthews and Gillespie were assaulted by Club Casino security after attempting entry without paying a cover charge; they were beaten, handcuffed, and taken outside as police were called.
- Lieutenant Anderson (shift commander) interacted with the scene, declaring control of the town; Greenlee arrived and relied on the Club owner Taylor for the account.
- Taylor stated Matthews struck him; Greenlee prepared complaints and arrested Matthews and Gillespie without informing them of arrest.
- Greenlee did not view the surveillance video, arguing probable cause existed from Taylor's account; the video reportedly would have shown the events but was not reviewed.
- The district court granted summary judgment on Counts 2 and 3; held probable cause defeated §1983 claims against City, Anderson, and Greenlee; dismissed state-law claims; concluded no conspiracy or municipal liability.
- Matthews and Gillespie appealed the grant of summary judgment, challenging the probable cause and supervisory/municipal liability rulings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was there probable cause to arrest Matthews and Gillespie? | Matthews (Gillespie) lacked individualized probable cause. | Greenlee reasonably relied on Taylor's credible account. | Yes; probable cause existed. |
| Was Lieutenant Anderson personally liable for the alleged false arrest? | Anderson encouraged or allowed the false arrest. | Anderson had minimal involvement. | No personal liability; no constitutional violation established. |
| Can the City be liable under §1983 for the alleged violations? | City had a policy, custom, or inadequate training causing harm. | No constitutional violation; no liability without Monell-like policy. | No municipal liability; probable cause defeats claim. |
| Does probable cause defeat a claim for malicious prosecution? | Lack of probable cause supports malicious-prosecution claim. | Probable cause defeats malicious-prosecution theory. | Probable cause defeats the claim. |
Key Cases Cited
- Woods v. City of Chicago, 234 F.3d 979 (7th Cir.2000) (probable cause standard and not needing exculpatory evidence after probable cause exists)
- Spiegel v. Cortese, 196 F.3d 717 (7th Cir.1999) (police not obligated to pursue exculpatory evidence after probable cause)
- Jenkins v. Keating, 147 F.3d 577 (7th Cir.1998) (probable cause sufficiency standard; credible witness informs officer)
- Eversole v. Steele, 59 F.3d 710 (7th Cir.1995) (probable cause inquiry guidance)
- Chavez v. Illinois State Police, 251 F.3d 612 (7th Cir.2001) (supervisor liability framework for personal involvement)
- Jones v. City of Chicago, 856 F.2d 985 (7th Cir.1988) (supervisor liability—know, facilitate, approve, or turn a blind eye)
- Monell v. Dep't of Social Services, 436 U.S. 658 ((1983)) (municipal liability requires policy or custom)
- City of Canton, Ohio v. Harris, 489 U.S. 378 (1989) (training dar and deliberate indifference standard)
- Thomas v. Cook County Sheriff's Dept., 604 F.3d 293 (7th Cir.2009) (explain municipal liability after police action and good-faith defenses)