Ray v. City of Chicago

Dist. Ct. did not err in granting defendants-City and police officer's motion to dismiss for failure to state claim in section 1983 action alleging that defendants violated plaintiff's 4th Amendment rights when they arrested and detained plaintiff on drug possession charge during time that defendant had been detained on traffic stop. Plaintiff could not maintain instant action where police had probable cause to believe that plaintiff had committed traffic offense, and thus it was irrelevant as to whether police had probable cause to arrest plaintiff on drug possession charge where she could have been arrested on traffic offense. Moreover, plaintiff's malicious prosecution claim was properly dismissed since plaintiff had state-court forum to address her claim. Plaintiff also could not recast malicious prosecution claim as Brady violation where plaintiff was never fully prosecuted on drug possession charge that was eventually dismissed.