Pedro Ramos v. City of Chicago, 716 F.3d 1013

Ramos was arrested in 2007 for residential burglary; he was acquitted in 2008.
The arrest followed a surveillance of a burglary at a South Lawndale address and an identification by a witness top the scene.
Officers detained Ramos during an investigatory stop after receiving a gang/gun-related description tied to the second suspect.
Garcia identified Ramos as the other intruder after Ramos was stopped; Ramos was then arrested.
Ramos filed a § 1983 action alleging false arrest and malicious prosecution plus state-law claims; the district court granted summary judgment for the defendants on § 1983 claims and declined supplemental jurisdiction over state claims.
The Seventh Circuit reviews de novo and affirms summary judgment if no genuine issues of material fact exist and defendants are entitled to judgment as a matter of law.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the initial vehicle stop was valid under Terry v. Ohio	Ramos argues the stop was not based on reasonable suspicion.	Officers had a description-based basis linking Ramos to the second suspect.	Yes; stop supported by reasonable suspicion under Terry.
Whether handcuffing Ramos transformed the stop into an arrest	Handcuffing during a brief stop escalated the encounter.	Handcuffs are permissible in some Terry stops for safety.	Court did not need to resolve this as probable cause existed for arrest due to license issue.
Whether probable cause existed to arrest Ramos after he failed to present a license	Probable cause relied on absence of license; other facts insufficient.	Failure to produce a license constitutes probable cause for arrest.	Yes; probable cause existed to arrest Ramos.
Whether the §1983 malicious prosecution claim was viable and damages available	False statements by officers could support a due-process claim and damages.	Illinois law provides state-law malicious-prosecution remedies; no cognizable due-process damages shown.	Summary judgment affirmed on the §1983 malicious-prosecution claim; damages lacking; no Fourth Amendment basis shown.

United States v. Patton, 705 F.3d 734 (7th Cir. 2013) (reasonable suspicion for Terry stop must be fact-specific)
Thayer v. Chiczewski, 705 F.3d 237 (7th Cir. 2012) (probable cause not required for Terry stop; reasonable suspicion suffices)
Gonzalez v. City of Elgin, 578 F.3d 526 (7th Cir. 2009) (probable cause considerations in arrests and related searches)
Abbott v. Sangamon County, 705 F.3d 706 (7th Cir. 2013) (probable cause can arise from violations other than the exact charged offense)
Fox v. Hayes, 600 F.3d 819 (7th Cir. 2010) (scope of Fourth Amendment claims in false arrest contexts)
Devenpeck v. Alford, 543 U.S. 146 (2004) (offense for probable cause need not be the offense charged)
Parish v. City of Chicago, 594 F.3d 551 (7th Cir. 2009) (Brady-like claim considerations against officers for evidence fabrication)
Tully v. Barada, 599 F.3d 591 (7th Cir. 2010) (limitations on officer-liability theories for misrepresented evidence)
Johnson v. Saville, 575 F.3d 656 (7th Cir. 2009) (limitations of Fourth Amendment theories in malicious-prosecution suits)
United States v. Bullock, 632 F.3d 1004 (7th Cir. 2011) (handcuffing and its role in Terry-stop characterization)
Clark v. United States, 657 F.3d 578 (7th Cir. 2011) (assessing whether handcuffing converts Terry stop into arrest)
United States v. Smith, 3 F.3d 1088 (7th Cir. 1993) (rare instances where handcuffs do not convert a stop into arrest)