Victor Watkins v. Anthony Martin
691 F. App'x 266
| 7th Cir. | 2017Background
- Watkins was arrested for burglary after DNA from blood found in the victim’s car matched him and the victim (Nurse) told police she did not know or authorize Watkins to be in her car.
- Officer Martin arrested Watkins without a warrant; Watkins moved in state court to quash the arrest for lack of probable cause.
- At the pretrial evidentiary hearing Watkins cross‑examined officers; the state court found probable cause and denied the motion to quash.
- Watkins proceeded to a bench trial; the same evidence (blood swab/DNA match, Nurse’s testimony about the car and lack of permission) was admitted, and Watkins was convicted and sentenced.
- Watkins later sued Martin under 42 U.S.C. § 1983 alleging arrest without probable cause. The district court granted summary judgment for Martin on issue preclusion grounds; this appeal followed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Watkins can litigate a § 1983 false‑arrest claim when a state court previously found probable cause at a pretrial hearing | Watkins: pretrial hearing was defective (missing witness testimony, withheld reports/photos), so he lacked a full and fair opportunity to litigate probable cause | Martin: state court already decided probable cause; issue preclusion (and Heck) bar relitigation of probable cause | Issue preclusion applies; Watkins had a full and fair opportunity and is precluded from relitigating probable cause (claim also would implicate Heck) |
| Whether Heck v. Humphrey bars Watkins’s § 1983 claim | Watkins: contends arrest lacked probable cause, implying no conviction validity issue | Martin: a favorable ruling would undermine the burglary conviction | Court: Claim necessarily implies invalidity of conviction; Heck would bar the claim (though decision rests on issue preclusion) |
Key Cases Cited
- Heck v. Humphrey, 512 U.S. 477 (1994) (a § 1983 claim that would invalidate a conviction is barred until conviction is overturned)
- Allen v. McCurry, 449 U.S. 90 (1980) (issue preclusion principles apply in § 1983 context)
- Kremer v. Chemical Construction Corp., 456 U.S. 461 (1982) (full and fair opportunity requirement for preclusion in civil rights cases)
- Brown v. City of Chicago, 599 F.3d 772 (7th Cir. 2010) (issue preclusion bars relitigation of issues decided in prior proceedings)
- Haywood v. Hathaway, 842 F.3d 1026 (7th Cir. 2016) (Heck bars § 1983 claims inconsistent with a conviction)
- Wiley v. City of Chicago, 361 F.3d 994 (7th Cir. 2004) (Heck bars false‑arrest claims when arrest and prosecution rest on the same evidence)
- Guenther v. Holmgreen, 738 F.2d 879 (7th Cir. 1984) (adversarial preliminary hearing can satisfy due process for probable‑cause determination)
- Talarico v. Dunlap, 685 N.E.2d 325 (Ill. 1997) (state law on issue preclusion and full and fair opportunity requirement)
Affirmed.