Marion Thomas v. Daniel McAuliffe, et al.

Summary

The United States Court of Appeals for the Seventh Circuit affirmed judgment for the defendants in Marion Thomas’s 42 U.S.C. § 1983 action arising from his arrest by Chicago police officers. The court held that the challenged jury instructions were not erroneous and that the district court did not abuse its discretion in denying a new trial based on the testimony concerning a marijuana grinder or defense counsel’s unanswered question about Thomas’s criminal record. The court concluded that probable cause for any crime could defeat the false-arrest claim and that the instructions adequately addressed obstruction and resistance.

Holdings

1. The instruction was not erroneous because probable cause to arrest for any crime defeats a false-arrest claim, even if the crime was not the offense invoked at the time of arrest.
2. The instructions, read as a whole, correctly and sufficiently informed the jury regarding Thomas's obligation to comply with the officers' commands and whether his conduct obstructed or resisted their authorized acts.
3. The district court did not abuse its discretion by refusing to grant a new trial under Federal Rule of Civil Procedure 60(b)(3) or its inherent sanctioning authority.
4. The unanswered question did not warrant a new trial because the district court sustained the objection, the criminal history was never presented to the jury, and the jury was instructed that lawyers' questions and comments were not evidence.

Questions Presented

1. Whether the jury instruction stating that probable cause to arrest for any crime defeats a false-arrest claim misstated the law.
2. Whether the jury instructions adequately explained the relationship between obstructing and resisting a law-enforcement officer under Illinois law.
3. Whether the district court abused its discretion by denying a new trial as a sanction for allegedly fraudulent or misleading testimony concerning a marijuana-related object.
4. Whether defense counsel's unanswered question about Thomas's criminal record required a new trial.

Disposition

affirmed