Summary
The Seventh Circuit considered § 1983 and Illinois false-arrest claims arising from warrantless arrests of Goldblatt employees and a friend based on information supplied by a private security employee. The court held that the police lacked probable cause and could not invoke a good-faith defense, but that the private defendants were not liable merely for furnishing information to the police. The court affirmed in part, reversed in part, and remanded for redetermination of attorneys’ fees.
Topics
Practice areas
Questions Presented
- Whether the warrantless arrests of the six Goldblatt employees were supported by probable cause under the Fourth Amendment and Illinois law.
- Whether the police officers were entitled to a good-faith defense under 42 U.S.C. § 1983.
- Whether Goldblatt's could be liable under Illinois law for false arrest and imprisonment merely because it supplied information to police.
- Whether Goldblatt's acted under color of state law or jointly with state officials for purposes of § 1983 liability based solely on furnishing information that led to Lewis's arrest.
- Whether the attorneys' fee award had to be redetermined after reversal of the verdicts against Goldblatt's.
Holdings
- The arrests were not supported by probable cause because the officers had no reasonable basis to regard the unidentified informant as reliable, failed to independently corroborate his allegations, and lacked firsthand knowledge supporting the arrests.
- The police officers were not entitled to a good-faith defense because they lacked a reasonable belief that the warrantless arrests were supported by probable cause and therefore constitutional.
- Goldblatt's was not liable for false arrest and imprisonment merely because it furnished information to police, where it did not detain the plaintiffs, sign complaints, or direct or procure the arrests.
- Goldblatt's did not act under color of state law or engage in joint activity with state officials merely by supplying information to police who independently decided to arrest Lewis.
- The case had to be remanded for redetermination of attorneys' fees consistent with the reversal of the verdicts against Goldblatt's.
Key quotations
“Accordingly, we have no difficulty in concluding that a reasonable man could not find that the arrests were based on probable cause.” (326)
“We decline to hold that the mere act of furnishing information to law enforcement officers constitutes “joint [activity] with state officials in the prohibited action”” (327)
Factual background
Goldblatt security personnel reported to Chicago police an alleged plot by Goldblatt employees to murder security officer Andre Walker. After Walker testified in court against a former employee, he told police that Earnest Lewis had threatened him, although no officer witnessed the alleged confrontation. Commander McDonald ordered the arrests of Lewis and the six employees without warrants; they were detained for three to fifteen hours and released when McDonald concluded the evidence was insufficient to charge them. Goldblatt's had supplied information to police but did not detain the plaintiffs, sign complaints, or direct the officers to arrest them.
Procedural history
The six Goldblatt employees and Earnest Lewis sued Chicago police officers and Goldblatt Bros. and its security personnel for arrests arising from alleged threats against a Goldblatt security officer. The district court directed a verdict against Officers McDonald and Juriss, granted Butler and Jenkins judgment notwithstanding the verdict against Officers Krause and Kowalski, and entered jury verdicts against Goldblatt's on certain state and federal claims. The Seventh Circuit affirmed the judgments against the police officers concerning the six employees, reversed the verdicts against Goldblatt's, and remanded for redetermination of attorneys' fees.
Remand instructions
Remand for redetermination of attorneys' fees consistent with the court's reversal of the judgments against Goldblatt's. The judgments against the police officers concerning the six employees were affirmed, while the verdicts against Goldblatt's on the state-law and § 1983 claims were set aside.