Sachin Gupta v. Chad Melloh
19 F.4th 990
7th Cir.2021Background
- Gupta, highly intoxicated and handcuffed with his hands behind his back in a hotel vestibule, was tugged by Officer Chad Melloh and fell face‑first, fracturing his C5 vertebra.
- Surveillance video (without audio) and a separate audio cellphone recording are in the record; the video is ambiguous but shows body movements and aftermath.
- Melloh asserts Gupta stiffened and actively resisted, justifying a forceful tug; Gupta contends he did not resist and was rendered especially vulnerable by intoxication and backhandcuffs.
- District court granted summary judgment for Melloh on federal and state claims (finding noncompliance and minimal force); Gupta appealed.
- The Seventh Circuit held there are material factual disputes (resistance, degree of force, Melloh’s awareness of Gupta’s impairment, and alleged falsification in the probable‑cause affidavit) that make summary judgment inappropriate and reversed and remanded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Excessive force (Fourth Amendment) | Gupta: was handcuffed, intoxicated, nonresisting; tug was excessive and caused serious injury | Melloh: Gupta resisted; tug was reasonable to overcome active resistance | Reversed; factual disputes about resistance and force preclude summary judgment and require factfinder resolution |
| Qualified immunity | Gupta: force was unlawful and clearly established under existing precedent | Melloh: actions were reasonable; qualified immunity applies | Reversed/remanded; cannot resolve qualified immunity on summary judgment because core facts are disputed |
| Alleged falsified probable‑cause affidavit / unlawful detention | Gupta: Melloh falsified facts supporting probable cause | Melloh: affidavit truthful; no unlawful detention | Reversed/remanded; resolution depends on contested facts (e.g., whether Gupta resisted) |
| State‑law battery (Indiana) | Gupta: state standard parallels federal excessive‑force rule; liability flows from disputed facts | Melloh: force was reasonable; immunity/authority under state law | Reversed/remanded; state claim rises or falls with same disputed facts as federal claim |
Key Cases Cited
- Graham v. Connor, 490 U.S. 386 (1989) (Fourth Amendment reasonableness test for excessive force)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (summary judgment standard—genuine dispute of material fact)
- Lujan v. Nat'l Wildlife Fed'n, 497 U.S. 871 (1990) (courts should not resolve genuine factual disputes on summary judgment)
- Pearson v. Callahan, 555 U.S. 223 (2009) (qualified immunity framework)
- Kisela v. Hughes, 138 S. Ct. 1148 (2018) (need to apply excessive‑force/qualified immunity in the specific factual context)
- Brosseau v. Haugen, 543 U.S. 194 (2004) (obvious cases can clearly establish law for qualified immunity)
- Manuel v. City of Joliet, Illinois, 137 S. Ct. 911 (2017) (Fourth Amendment claim for unlawful detention/prosecution)
- Franks v. Delaware, 438 U.S. 154 (1978) (veracity requirement for affidavits supporting probable cause)
- Abdullahi v. City of Madison, 423 F.3d 763 (7th Cir. 2005) (excessive‑force cases rarely appropriate for summary judgment due to disputed facts)
- Payne v. Pauley, 337 F.3d 767 (7th Cir. 2003) (courts must not weigh credibility or resolve swearing contests at summary judgment)