Shaun J. Matz v. Rodney Klotka
2014 U.S. App. LEXIS 19074
7th Cir.2014Background
- On Sept. 16, 2003, Officers Klotka and Zuberbier (warrant squad, in uniform in an unmarked car) observed a group on a porch that included Javier Salazar, a wanted Latin Kings member. The group dispersed as officers approached.
- Officers chased people leaving the porch, stopped a vehicle containing Shaun Matz, drew weapons, ordered occupants out, handcuffed Matz, and placed him in a patrol car; backup units arrived shortly thereafter.
- Officers soon learned the vehicle Matz was driving was stolen; Salazar was later arrested inside the residence. Matz was taken to jail, interrogated over multiple sessions, and eventually gave an inculpatory statement he later recanted. He pleaded guilty and received lengthy consecutive sentences.
- Matz sued under 42 U.S.C. § 1983 claiming Fourth Amendment violations (unreasonable stop/arrest; lack of prompt judicial probable-cause determination) and Fifth Amendment violations (continued interrogation after invocation of right to remain silent/coerced confession).
- The district court granted summary judgment to defendants. The Seventh Circuit reviewed de novo, construing facts in Matz’s favor, and affirmed summary judgment on all claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether officers had reasonable suspicion to stop/detain Matz (Terry stop) | Matz: no particularized suspicion beyond proximity to Salazar and leaving the porch; stop was an unjustified seizure | Officers: particularized suspicion as to Salazar plus flight, proximity, risk he could be hidden in the car justified a Terry stop | Held: Totality of circumstances gave reasonable suspicion to detain and stop the vehicle |
| Whether the detention was a de facto arrest (requiring probable cause) due to force, handcuffs, guns, duration | Matz: pointing guns, threats, handcuffs, placement in car converted detention into arrest before probable cause | Defs: force and handcuffs were reasonable given risk (suspected armed violent fugitive, moving vehicle, officers outnumbered); officers diligently pursued info; probable cause arose quickly (stolen car) | Held: Use of force was at the outer edge but reasonable under circumstances; detention did not become an unlawful arrest before probable cause |
| Whether Matz received a timely judicial probable-cause determination (Gerstein/Riverside) | Matz: Milwaukee practice of relying on arrest-detention reports with unsworn statements denied a prompt judicial determination; the report relied on possibly coerced statements | Defs: Commissioners’ report (including sworn portions) showed a probable-cause determination within 48 hours; named officers did not author or present the report and lack personal involvement | Held: Plaintiffs failed to show defendants personally caused a Fourth Amendment deprivation; summary judgment for defendants on the Riverside claim |
| Whether post-invocation/continued interrogation produced coerced confession giving rise to damages (Fifth Amendment) | Matz: interrogations continued after he invoked rights, produced coerced confession used at sentencing | Defs: Even assuming coercion, success would invalidate conviction/sentence; Heck bar applies | Held: Heck bars damages because Matz’s conviction and sentence (which relied on his confession) remain valid |
Key Cases Cited
- Terry v. Ohio, 392 U.S. 1 (1968) (authorizes brief investigatory stops on reasonable suspicion)
- Whren v. United States, 517 U.S. 806 (1996) (objective-reasonableness test for seizures regardless of officers’ subjective motives)
- Gerstein v. Pugh, 420 U.S. 103 (1975) (Fourth Amendment requires timely judicial probable-cause determination following arrest)
- County of Riverside v. McLaughlin, 500 U.S. 44 (1991) (probable-cause determinations within 48 hours are presumptively prompt)
- Heck v. Humphrey, 512 U.S. 477 (1994) (§ 1983 damages barred if success would imply invalidity of an unrevoked conviction/sentence)
- Illinois v. Wardlow, 528 U.S. 119 (2000) (flight in a high-crime area can contribute to reasonable suspicion)
- Harlow v. Fitzgerald, 457 U.S. 800 (1982) (qualified immunity test: protection unless officer violated clearly established law)
- Brendlin v. California, 551 U.S. 249 (2007) (passengers are seized when the vehicle is stopped in an investigation)
- United States v. Sharpe, 470 U.S. 675 (1985) (courts should avoid unrealistic second-guessing of police in rapidly developing situations)
- Dunaway v. New York, 442 U.S. 200 (1979) (formal arrests require probable cause)