Madero v. McGuinness, No. 23-2574 (7th Cir. 2024)
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In the early hours of a snowy morning, police officer Owen McGuinness responded to a hit-and-run accident in Rockford, Illinois. Upon arrival, he received conflicting accounts from Daniel Madero, who was accused of being the driver of the hit-and-run vehicle, and three witnesses who claimed they had followed the vehicle and identified Madero as the driver. Madero was arrested for aggravated battery and issued traffic citations. An investigation later concluded that Madero's vehicle was likely not involved in the hit-and-run accident, and no charges were pressed against him.
Madero subsequently filed a federal complaint claiming false arrest in violation of the Fourth and Fourteenth Amendments. The district court granted summary judgment to Officer McGuinness, determining that he had probable cause to arrest Madero based on the information available at the time.
The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The court concluded that Officer McGuinness had probable cause to arrest Madero given the testimony of the three witnesses who insisted that Madero was the driver of the hit-and-run vehicle, despite Madero's denial. Discrepancies in the witnesses' accounts and later recantations did not dispel the probable cause at the time of arrest. Therefore, Madero's claim of false arrest was rejected.
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