Ronald Fosnight v. Robert Jones, 41 F.4th 916

Paraklese Technologies (owner Ronald Fosnight) manufactured and sold solvent traps—cleaning accessories that can be converted into silencers—at a facility in Georgetown, Indiana.
On June 20, 2017 ATF agents (with Indiana State Police) executed a federal magistrate-issued search warrant and seized about $21,000 of inventory; ATF retained the items for over 24 months.
Fosnight alleges ATF presented (but did not produce) a "determination letter" concluding the traps were illegal silencer parts; he also alleges persistent interrogation without Miranda warnings and warnings about losing his federal firearms license.
In June 2019 Fosnight and Paraklese filed a Bivens suit against named and unnamed ATF agents asserting Fourth Amendment and Fifth Amendment due-process claims seeking damages.
The district court took judicial notice of the search warrant, held the complaint failed to plausibly allege any constitutional violation or personal involvement by many defendants, rejected the due-process theory, found qualified immunity applicable, denied leave to amend, and dismissed with prejudice.
The Seventh Circuit affirmed: judicial notice was proper; a warranted search is presumptively valid; Miranda omissions do not support Bivens damages; no viable due-process theory was pleaded; qualified immunity and denial of leave to amend were correct.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Judicial notice of warrant	Warrant should not be judicially noticed or its validity disputed	Warrant is a public court document; judicial notice under Fed. R. Evid. 201 is proper on 12(b)(6)	Court may take judicial notice of the warrant; doing so was proper
Fourth Amendment search/seizure validity	Search/seizure unlawful; ATF conduct violated Fourth Amendment	Search was executed under a federal magistrate-issued warrant; warranted searches are presumptively valid	Complaint failed to plead facts plausibly rebutting warrant's validity or scope; Fourth Amendment claim dismissed
Interrogation / Miranda / Fifth Amendment	Agents interrogated Fosnight without Miranda; this supports constitutional claim	Failure to give Miranda warnings is not a Fourth Amendment injury and is not actionable as Bivens damages	Miranda is a prophylactic rule tied to trial exclusion; Vega forecloses damages for Miranda violations; claim fails
Due process, personal liability, qualified immunity, amendment	Due-process claim for seizure; various agents liable; requested leave to amend	No plausible due-process theory pleaded; many defendants lack allegations of personal involvement; qualified immunity; plaintiff failed to meaningfully seek amendment	Due-process claim waived/unsupported; Bivens requires personal involvement; qualified immunity applies; denial of leave to amend was within discretion; dismissal affirmed

Bivens v. Six Unknown Named Agents of the Federal Bureau of Narcotics, 403 U.S. 388 (U.S. 1971) (recognized an implied damages remedy against federal officers)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (U.S. 2007) (plausibility pleading standard for complaints)
Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (apply Twombly plausibility test to individual-capacity claims)
Ziglar v. Abbasi, 137 S. Ct. 1843 (U.S. 2017) (limits on judicially expanding Bivens remedies)
Vega v. Tekoh, 142 S. Ct. 2095 (U.S. 2022) (Miranda violations are not a basis for damages against officers)
Harlow v. Fitzgerald, 457 U.S. 800 (U.S. 1982) (qualified immunity framework)
Archer v. Chisholm, 870 F.3d 603 (7th Cir. 2017) (search pursuant to a warrant is presumptively valid)
Gen. Elec. Capital Corp. v. Lease Resolution Corp., 128 F.3d 1074 (7th Cir. 1997) (judicial notice of public records on dismissal motions)
Ennenga v. Starns, 677 F.3d 766 (7th Cir. 2012) (public-record judicial notice need not convert Rule 12(b)(6) motion into summary-judgment)
Groh v. Ramirez, 540 U.S. 551 (U.S. 2004) (particularity requirement for search warrants)