Octavia Mitchell v. City of Chicago, 862 F.3d 583

On April 24, 2010, Chicago officers stopped a car for a missing front license plate; passenger Izael Jackson fled and was shot in the back by officers and died the next day.
Officers testified Jackson fired at them; evidence at trial included gunshot residue on Jackson’s hand and 16 shell casings matching the recovered Glock Model 19.
Crime-scene personnel took DNA swabs from the recovered Glock, but the Illinois State Police never tested the swabs and Mitchell (Jackson’s mother/plaintiff) did not arrange testing or identify expert challengers.
Mitchell sued for excessive force (Fourth Amendment) and wrongful death under Illinois law; the jury found for the City and the shooting officers who fired.
Mitchell moved for a new trial arguing the district court erred by quashing a subpoena to the Illinois State Police and by excluding argument/evidence about the lack of DNA testing. The district court denied relief; Mitchell appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether district court abused discretion by quashing Mitchell's subpoena to Illinois State Police (untimely discovery)	Mitchell: subpoena was necessary to obtain info/testing that could show Jackson did not hold the gun and thus negate officers' fear	City: subpoena was served months after discovery cutoff with no good cause; testing decisions were made by Illinois State Police, not City	Court: No abuse of discretion — subpoena untimely; Mitchell failed to show good cause for delay
Whether district court erred by excluding evidence/argument that DNA swabs were not tested (alleged investigatory cover-up/relevance)	Mitchell: failure to test could show absence of Jackson's DNA on gun and support claim gun did not belong to him; testing omission suggested cover-up	City: lack of testing was irrelevant to officers' state of mind at time of shooting and unfairly prejudicial; testing decision was by a separate state agency	Court: Evidence/examination about lack of DNA testing was irrelevant to whether officers reasonably feared harm and properly excluded

Ott v. City of Milwaukee, 682 F.3d 552 (7th Cir.) (standard: abuse of discretion review for quashing subpoenas)
Wollenburg v. Comtech Mfg. Co., 201 F.3d 973 (7th Cir.) (district courts may enforce discovery deadlines and deny belated requests)
Wilson v. City of Chicago, 758 F.3d 875 (7th Cir.) (qualified-immunity/Fourth Amendment deadly-force framework and appellate review scope)
Perry v. City of Chicago, 733 F.3d 248 (7th Cir.) (standard for reversing evidentiary rulings: abuse of discretion and prejudice)
Tennessee v. Garner, 471 U.S. 1 (1985) (deadly force use limits: officer must reasonably believe suspect poses serious threat)
Thompson v. City of Chicago, 472 F.3d 444 (7th Cir.) (§1983 protects against constitutional violations, not mere procedural/regulatory violations)