White v. City of Chicago

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From 2008-2010, the FBI and Chicago Police Department conducted a narcotics investigation, “Operation Blue Knight.” As the operation was wrapping up, Officer O’Donnell applied for dozens of arrest warrants, including one for White. Other officers had observed White and his brother sell heroin to an informant. The observations were in a more comprehensive report (NAGIS) that O’Donnell used as the basis for his arrest warrant application. White was arrested, but the charge was dropped. He then brought a civil rights lawsuit alleging that O’Donnell’s actions and a city policy violated his Fourth Amendment rights. White’s claims are based on a theory that O’Donnell failed to present the judge who issued the warrant enough information to establish probable cause for the arrest. The district court dismissed the claims. The Seventh Circuit affirmed. O’Donnell’s written application for an arrest warrant, supported by his oral testimony about the NAGIS report of the surveillance of the drug deal, provided probable cause for the warrant. Probable cause also establishes that White did not suffer a constitutional injury, which was a necessary element of his “Monell claim” against the city. View "White v. City of Chicago" on Justia Law