Bailey 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 lacked probable cause to arrest plaintiff on murder charge, where defendants based plaintiff’s arrest on statements from two witnesses identifying plaintiff as culprit from videotape of crime scene. While plaintiff claimed that it was unreasonable for defendants to believe that any witness could have credibly identified him from poor quality of video, defendants could have reasonably found that said identifications were credible, where witnesses knew plaintiff in some capacity and had allegedly spent time with plaintiff on day of incident. Moreover, plaintiff’s alibi claim appeared to be weak. Fact that identifications proved to be wrong was irrelevant to probable cause finding. Also, plaintiff failed to show that his 47-hour detention prior to his probable cause hearing was unreasonable.