Patrick v. City of Chicago

Dist. Ct. erred in dismissing on collateral estoppel grounds portion of plaintiff’s section 1983 action, alleging that defendants-police officials unlawfully searched and seized firearms from his hone, where seizure of said firearms eventually led to filing of series of criminal charges, and where plaintiff eventually pleaded guilty to charge of aggravated discharge of weapon. While Dist. Ct. believed that plaintiff’s search and seizure claim was collaterally estopped due to unfavorable ruling in prior action, said prior action did not concern any search and seizure claim, but rather pertained only to plaintiff’s contention that State of Illinois and Cook County Dept. of Corrections were holding him under false pretenses. Moreover, prior action did not resolve whether instant warrantless search of defendant’s home and seizure of his property were justified. Dist. Ct., though, properly dismissed plaintiff’s unlawful detention claim, where: (1) said claim is Heck-barred because it would necessarily imply invalidity of his conviction; and (2) plaintiff lacked standing to pursue claim that his five-year pre-trial detention was unlawful, where said period was credited to his valid sentence on his conviction for aggravated discharge of weapon, and where section 1983 plaintiff could not receive damages for time spent in custody that was credited to valid sentence.