Sara Bridewell, Randy Manuel, and Lisa Rhodes v. Kevin Eberle, Brian Forberg, and City of Chicago, Illinois

Summary

The Seventh Circuit affirmed summary judgment for Chicago police detectives and the City of Chicago on claims arising from the plaintiffs’ arrests and investigation of Walter Chandler’s homicide. The court held that the officers had probable cause to arrest the plaintiffs, that Sara Bridewell suffered no compensable injury from the delay in her probable-cause hearing, and that her malicious-prosecution and intentional-infliction-of-emotional-distress claims failed. Judge Wood concurred in the judgment while expressing reservations concerning aspects of the majority’s reasoning.

Holdings

1. The officers had probable cause to arrest the plaintiffs because the facts known or reasonably inferred at the time supported a fair probability that one or more of them had committed the murder or aided the killer.
2. Bridewell could not recover damages for the 63-hour delay because she failed to show injury attributable to the delay.
3. Bridewell could not establish the favorable-termination element of Illinois malicious prosecution because the murder charge was dismissed as part of a plea bargain, and she identified no Illinois authority permitting a court to look beyond the bargain to determine whether the charge otherwise would have been dismissed.
4. Bridewell's Illinois intentional-infliction-of-emotional-distress claim was barred by the one-year statute of limitations and did not accrue anew merely because the alleged effects or inaction continued.

Questions Presented

1. Whether the officers had probable cause to arrest Bridewell, Manuel, and Rhodes for Chandler's murder or aiding the killer.
2. Whether Bridewell was injured by the 63-hour delay before her probable-cause hearing in violation of the Fourth Amendment.
3. Whether dismissal of the murder charge as part of a plea bargain constituted a favorable termination implying innocence for purposes of an Illinois malicious-prosecution claim.
4. Whether Bridewell's Illinois intentional-infliction-of-emotional-distress claim was timely or accrued anew based on the defendants' continuing alleged inaction.

Disposition

affirmed