Scott Rabin v. Michael Flynn
2013 U.S. App. LEXIS 13802
7th Cir.2013Background
- Rabin, a licensed private investigator, was stopped in Illinois after officers observed a holstered gun and Rabin produced a tan card authorizing carrying a firearm.
- Flynn confiscated Rabin’s loaded gun and sought to verify the tan card through LEADS, learning it could not be verified and that Springfield had no information about it.
- Knepper arrived, confirmed Rabin was the armed individual, and detained Rabin by handcuffing and moving him to a vehicle; Quinlan then arrived and Rabin was placed in a cage car for transport.
- Rabin requested looser handcuffs and noted preexisting neck and hand medical issues; Knepper did not loosen the restraints.
- Rabin was detained for about 90 minutes before Lake County State’s Attorney’s Office confirmed Rabin could lawfully carry the gun and released him; Rabin alleged injuries from the handcuffs.
- Rabin sued Flynn, Knepper, Quinlan, and others under §1983 for unlawful arrest and excessive force; district court denied immunity in part, and this appeal concerns only the officers’ qualified-immunity defenses.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether detaining Rabin without immediate release violated the Fourth Amendment | Rabin argues tan card proves lawful carry; immediate release required | Officers may detain to verify license; not obvious release required; safety concerns persist | Qualified immunity; detention reasonable pending verification |
| Whether officers’ handcuffing constituted excessive force given Rabin's medical conditions | Tight handcuffs exacerbated medical issues; Knepper knew of conditions | Generalized discomfort without specific medical alerts insufficient | Knepper not immune on excess claim; Flynn and Quinlan immune; facts show Rabin’s specific conditions supported claim against Knepper |
| Whether the prolonged verification process and systemic failures negate individual officer liability | System-wide failures caused delay; officers should be responsible | Delays due to systemic inefficiencies outside officers’ control | Detention justified; no individual officer liability for systemic verification delays |
Key Cases Cited
- United States v. McDonald, 453 F.3d 958 (7th Cir. 2006) (police mistake of law cannot support probable cause for a stop)
- Pritchard v. Hamilton Twp. Bd. of Trustees, 424 Fed.Appx. 492 (6th Cir. May 25, 2011) (lawful supervision can justify temporary detention when parental status unknown)
- United States v. Glenna, 878 F.2d 967 (7th Cir. 1989) (handcuffs during Terry stop limited to rare safety situations)
- Bullock, 632 F.3d 1004 (7th Cir. 2011) (handcuffs may be justified to prevent flight or ensure safety during questioning)
- Arizona v. Evans, 514 U.S. 1 (S. Ct. 1995) (limitations on arrest and detention under the Fourth Amendment)