False Arrest

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7^th Circuit Court of Appeals

Case Name: Daniel Madero v. Owen McGuinness

Case No.: 23-2574

Officials: Sykes, Chief Judge, and Ripple and St. Eve, Circuit Judges.

Focus: False Arrest

In the early hours of a snowy morning, Officer Owen McGuinness responded to a hit-and-run accident in Rockford, Illinois. Upon arrival, he encountered conflicting reports from Daniel Madero, who was accused of being the driver of the fleeing vehicle, and three witnesses who claimed to have trailed the vehicle and identified Madero as the driver. Subsequently, Madero was arrested for aggravated battery and issued traffic citations. However, an investigation later determined that Madero’s vehicle was likely not involved in the hit-and-run incident, leading to no charges being brought against him.

Following these events, Madero filed a federal complaint alleging false arrest, citing violations of the Fourth and Fourteenth Amendments. The district court ruled in favor of Officer McGuinness, granting summary judgment and asserting that he had probable cause for Madero’s arrest based on the available information at the time.

The Seventh Circuit upheld the district court’s decision, affirming that Officer McGuinness had sufficient probable cause to arrest Madero. This conclusion was primarily based on the testimony of the three witnesses who strongly asserted Madero’s involvement as the hit-and-run driver, despite Madero’s denials. Even discrepancies in the witnesses’ statements and subsequent retractions did not diminish the existence of probable cause at the time of Madero’s arrest. Consequently, Madero’s claim of false arrest was dismissed.

Affirmed.

Decided 04/01/24

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