Sara Bridewell v. Kevin Eberle
2013 U.S. App. LEXIS 17924
| 7th Cir. | 2013Background
- Hit-and-run chase ends with Chandler dead in alley after confrontation with Rhodes, Bridewell, Manuel, and Watkins; police later arrest Bridewell, Rhodes, Manuel, Watkins; Bridewell charged with murder and later pled guilty to drug charge, murder charge dismissed by nolle prosequi; plaintiffs sue under 42 U.S.C. §1983 alleging unlawful arrests; district court grants summary judgment to Eberle, Forberg, and City on all claims.
- District court found probable cause to arrest the plaintiffs; evidence included a dead body, witness statements, and the group’s confrontation of Chandler; the medical examiner’s initial homicide finding and holes in Chandler’s head supported probable cause inference.
- Plaintiffs argue jurors should independently assess probable cause; they argue possible alternative scenarios undermine officers’ beliefs; defendants argue officers had a reasonable fair-probability belief based on the at-scene facts.
- Court holds: there was probable cause to arrest based on what officers reasonably believed at the time; deference to police judgments at the scene is proper; retrospective counterarguments do not defeat probable cause.
- Bridewell-specific claims addressed: Riverside timing issue, malicious prosecution, and intentional infliction of emotional distress.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Probable cause to arrest all plaintiffs | Bridewell argues jurors should assess probable cause independently | Defendants contend officers had reasonable probable cause at the time | Probable cause found; officer beliefs supported by scene facts |
| Riverside 48-hour rule violation and damages | Bridewell alleges 63-hour detention violated Riverside | Detention delay caused no injury given bail status and eventual disposition | No injury; no damages awarded for Riverside delay |
| Malicious prosecution against officers | Dismissal via nolle prosequi implied innocence | Pleas and bargains do not inexorably imply innocence; Illinois law governs | Dismissal under plea bargain does not establish innocence; no malicious-prosecution liability |
| Intentional infliction of emotional distress accrual | Ongoing detention and post-charge actions can renew claim | Claims time-barred; actions after indictment insufficient | Claims time-barred; not renewed by ongoing conduct; affirmance of dismissal |
| Other state-law claims (emotional distress, etc.) | Affirmed dismissal; district court proper on state-law claims |
Key Cases Cited
- Illinois v. Gates, 462 U.S. 213 (U.S. Supreme Court, 1983) (probable cause involves a fair probability based on totality of circumstances)
- County of Riverside v. McLaughlin, 500 U.S. 44 (U.S. Supreme Court, 1991) (4th amendment prompt probable-cause hearing within 48 hours; purposes include preventing unfounded detention)
- Dunn v. City of Chicago, 231 F.R.D. 367 (N.D. Ill. 2005) (class-action Riverside violations; relevance to damages/scope)
- Swick v. Liautaud, 169 Ill.2d 504 (Ill. Supreme Court, 1996) (plea bargain does not automatically negate innocence in malicious-prosecution context)
- Evans v. City of Chicago, 434 F.3d 916 (7th Cir., 2006) (accrual and continuing-status principles for emotional-distress claims in arrest/prosecution context)
- Carey v. Piphus, 435 U.S. 247 (U.S. Supreme Court, 1978) (procedural due-process damages; nominal damages possible for procedural deprivations)
- Kato v. National City, 549 U.S. 384 (U.S. Supreme Court, 2007) (continuing violations and accrual principles in procedural contexts)
- Pulungan v. United States, 722 F.3d 983 (7th Cir., 2013) (illustrates limits on inferring innocence from negative outcomes in prosecutorial decisions)