Stokes v. Board of Education of the City of Chicago

Dist. Ct. did not err in granting defendants' (school principal and school board) motion for summary judgment in section 1983 action alleging that defendants improperly initiated criminal complaints, which resulted in false arrests of plaintiffs in school office after plaintiffs and third-parties were involved in physical and verbal altercation in front of kindergarten students. While plaintiffs presented evidence indicating that third-parties were physical aggressors in altercation, principal had probable cause to sign criminal complaints calling for plaintiffs' arrests on charge of disorderly conduct where principal witnessed plaintiffs engaging in loud profanity in front of school children, and where plaintiffs had frustrated principal's attempt to restore order in school building. Moreover, while principal undertook only limited investigation, principal was not required to conduct full investigation prior to signing complaints where need to restore order and diminish potential harm to students was high.