Mathews v. City of East St. Louis

Dist. Ct. did not err in granting defendants-police officials’ motion for summary judgment in section 1983 action alleging that defendants lacked probable cause to arrest plaintiffs on assault and battery charges arising out of incident that occurred at local night club. Defendants had probable cause to arrest plaintiffs based on defendants’ interview with owner of club, who asserted that plaintiffs had attempted to enter club without paying cover charge and had initiated fight with security guards after they had been asked to leave. Fact that plaintiffs asserted that security guards had initiated fight, and that club had security camera would have recorded the incident did not require different result since police are not required to search for exculpatory evidence once probable cause has been established. Moreover, while both plaintiffs were visibly beaten, said fact did not indicate that club owner was lying with respect to claim that plaintiffs had initiated fight.