White v. City of Chicago

Dist. Ct. did not err in granting defendants-police officials’ motion for summary judgment in section 1983 action alleging that defendants violated plaintiff’s 4^th Amendment rights by failing to present judge, who issued arrest warrant, with sufficient facts to establish probable cause to support drug delivery charge that was eventually dismissed. Defendant was arrested after police observed him and another individual interact with confidential informant who subsequently told police that he purchased drugs from said men. Moreover, while information contained in standard complaint form concerning factual background for instant drug delivery charge was insufficient to establish probable cause to support issuance of arrest warrant, officer testified that he gave sworn statement to judge that defendant was involved in narcotics transaction that was based on contents of detailed police report that did provide sufficient facts to establish probable cause for plaintiff’s arrest. Fact that officer could not recall all facts that he told judge did not require different result. Moreover, plaintiff could not assert any Monell claim against city itself where he could not establish 4^th Amendment claim against officers.