Uche Mordi v. Todd Zeigler, 2014 U.S. App. LEXIS 20744

Mordi, a Nigerian national, was arrested on March 12, 2009 after a vehicle stop and dog-detected drugs.
Zeigler arrested Mordi, took him to a police station, and left him in an interrogation room.
Chance and Healey interviewed Mordi that afternoon; Zeigler later transported him to Effingham County Jail for booking.
Mordi told Chance and Healey he was Nigerian; Chance recorded Nigerian nationality on a form.
No one informed Mordi of his consular rights under Article 36 during state or federal proceedings; he learned of the rights years later and sought relief under 42 U.S.C. §1983.
The district court denied summary judgment re: qualified immunity for three officers; on appeal, the Seventh Circuit addresses whether qualified immunity applies because the rights were clearly established.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Article 36 rights were clearly established for personal liability.	Mordi argues Jogi II shows Article 36 creates individual rights actionable under §1983.	Officers argue no clearly established right was violated; the law was not clearly established for their particular conduct.	No clearly established right found; officers entitled to qualified immunity.

Pearson v. Callahan, 555 U.S. 223 (2009) (sets framework for qualified-immunity analysis)
Anderson v. Creighton, 483 U.S. 635 (1987) (requires specific, not overly general, rights to be clearly established)
Plumhoff v. Rickard, 134 S. Ct. 2012 (2014) (limits use of general principles; focus on reasonable actions in context)
Saucier v. Katz, 533 U.S. 194 (2001) (former sequencing of constitutional question and clearly established law)
Reichle v. Howards, 132 S. Ct. 2088 (2012) (emphasizes context-specific reasonable conduct)
Medellín v. Texas, 552 U.S. 491 (2008) (discusses the meaning of ‘without delay’ in consular notification)