Elias Villalobos v. Louis Picicco

CourtCourt of Appeals for the Seventh Circuit
DecidedMarch 6, 2026
Docket25-1304
StatusPublished
AuthorBrennan

This text of Elias Villalobos v. Louis Picicco (Elias Villalobos v. Louis Picicco) is published on Counsel Stack Legal Research, covering Court of Appeals for the Seventh Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Elias Villalobos v. Louis Picicco, (7th Cir. 2026).

Opinion

In the

United States Court of Appeals For the Seventh Circuit ____________________ No. 25-1304 ELIAS VILLALOBOS, Plaintiff-Appellee, v.

LOUIS PICICCO, et al., Defendants-Appellants. ____________________

Appeal from the United States District Court for the Northern District of Illinois, Eastern Division. No. 1:16-cv-08510 — Franklin U. Valderrama, Judge. ____________________

ARGUED DECEMBER 10, 2025 — DECIDED MARCH 6, 2026 ____________________

Before BRENNAN, Chief Judge, and LEE and KOLAR, Circuit Judges. BRENNAN, Chief Judge. This constitutional tort case comes to us in a peculiar procedural posture. In 2015, Calumet City, Illinois police officers tased and shot Elias Villalobos in his home. Villalobos sued the officers under 42 U.S.C. § 1983, al- leging violations of the Fourth Amendment. At the summary judgment stage, the officers invoked qualified immunity. But the district court largely rejected that affirmative defense, 2 No. 25-1304

finding that nearly all Villalobos’s excessive force theories of liability should go to trial. In the district court’s view, a jury must resolve fact disputes central to the officers’ qualified im- munity defense. The district court also decided one issue as a matter of law. It concluded that the officers violated the Fourth Amendment when they entered Villalobos’s home without a warrant. Un- convinced by the officers’ argument that they faced exigent circumstances, the court rejected their qualified immunity de- fense and granted partial summary judgment to Villalobos. The officers then brought this interlocutory appeal, challeng- ing only the district court’s analysis of that issue. For the reasons stated below, we vacate the district court’s order on the unlawful entry issue and remand for further pro- ceedings. On remand, the parties should advance arguments on both prongs of the qualified immunity test, not just one. We also respectfully invite the district court to consider the implications of some factual disputes identified by the parties on appeal. I A. Undisputed Facts In May 2015, Officer Louis Picicco drove to the home of Elias Villalobos in Calumet City. He was responding to a 911 call about a man throwing a knife in an alley near the house. When Picicco arrived, he spoke to the 911 caller, who pointed out the alleged knife-thrower. Picicco says he watched the man enter the house through the front door, but he did not see anything in the man’s hands. After Officer Kyle Brasewicz arrived, the two officers knocked on Villalobos’s front door. They then exchanged No. 25-1304 3

words with at least one person, who told the officers from be- hind the closed door to go away. At least two things happened next. First, Officer Fernando Guerrero and Sergeant Kevin Urbanek arrived sometime fol- lowing the exchange at the door. Second, some of the officers interacted with two other people outside the house who did not appear injured or in distress. The officers also learned (at some point during the encoun- ter) about a domestic violence incident linked to Villalobos’s address. A few days earlier, a woman had reported Villalobos to the Calumet City Police Department, accusing him of “choking her in the shower, putting a gun to her head and threatening to kill her, and accusing her of stealing drugs from him.” Based on the information the officers had gathered, they decided to enter Villalobos’s home through the unlocked back door without a warrant. In their telling, they did so to conduct a well-being check and to ensure the safety of occupants. Vil- lalobos contends this was a “pretext” designed to “grab” him illegally in his own home. Once inside the house, the officers searched for the man Picicco saw earlier. In the kitchen, they encountered a woman who did not appear injured. On the second floor, they found Villalobos hiding in a crawl space in the bedroom closet. Both sides strongly dispute what happened next. The of- ficers contend Villalobos refused to comply with their com- mands and threatened them with an electric drill, a stick, and a knife. Villalobos insists he did none of these things. But all agree the officers tased Villalobos several times before Picicco shot him. 4 No. 25-1304

B. Procedural History Villalobos sued Picicco, Brasewicz, Guerrero, and Ur- banek for their roles in this incident. Villalobos’s pro se amended complaint did not explain the legal theory of his lawsuit. Once he obtained counsel, the parties distilled two claims from his account. 1 A series of Fourth Amendment ex- cessive force theories of liability became the centerpiece of the lawsuit. By tasing him several times, Villalobos argued, each officer had acted unreasonably because he had not resisted their commands or threatened them. He also asserted that Picicco had no reasonable grounds for shooting him because he did not wield a knife at the officers. Villalobos also alleged the officers violated his Fourth Amendment right to be free of a “warrantless and nonconsen- sual entry” into his home. Payton v. New York, 445 U.S. 573, 576 (1980). The officers, however, believed the exigent circum- stances exception to the warrant requirement justified their entry. There had been a prior domestic violence incident at the house, and some officers claimed they heard a woman’s voice from behind the door say she could not open it. So, un- der the totality of circumstances, the officers decided to con- duct a well-being check for the physical safety of individuals who might be inside. At the close of discovery, the officers moved for summary judgment. They invoked qualified immunity as an affirmative defense to all Villalobos’s Fourth Amendment challenges. But the district court largely denied this motion. Though it de- cided Picicco could not be held liable for the first deployment

1 Villalobos voluntarily dismissed his third theory, a false arrest argu-

ment, at the summary judgment stage. No. 25-1304 5

of his taser, the court rejected the officers’ motion on all other excessive force arguments. It found several disputes of mate- rial fact on issues core to the immunity defense, precluding summary judgment. These are issues for trial on remand. The district court handled the unlawful entry theory dif- ferently. Villalobos had moved for partial summary judgment on this issue, contending the officers had not shown an emer- gency justifying their warrantless entry. Agreeing with Villa- lobos, the district court simultaneously rejected the officers’ qualified immunity defense and entered partial summary judgment for Villalobos on the unlawful entry component. The officers then filed this interlocutory appeal. They chal- lenge only the portion of the district court’s order denying them qualified immunity on Villalobos’s unlawful entry claim. The officers do not ask us to revisit the grant of partial summary judgment to Villalobos, nor do they appeal the dis- trict court’s handling of the excessive force claims. We review a denial of summary judgment de novo. Smith v. Finkley, 10 F.4th 725, 734 (7th Cir. 2021). In other words, we examine the record to see whether the district court properly rejected the defendants’ qualified immunity defense. Id. When the facts require us to draw inferences, they are con- strued in favor of the non-moving party, Villalobos. Doe v. Gray, 75 F.4th 710, 716 (7th Cir. 2023). II As always, we begin with jurisdiction. Chi. Tchrs. Union, Loc. 1 v. Educators for Excellence, Inc., 159 F.4th 524, 528 (7th Cir. 2025). We have no reason to doubt the district court’s ju- risdiction to hear the underlying dispute. See 28 U.S.C. § 1331. 6 No. 25-1304

But this court must also ensure it has appellate jurisdiction. Smith, 10 F.4th at 734–35.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Estate of Escobedo v. Bender
600 F.3d 770 (Seventh Circuit, 2010)
Payton v. New York
445 U.S. 573 (Supreme Court, 1980)
Mitchell v. Forsyth
472 U.S. 511 (Supreme Court, 1985)
Johnson v. Jones
515 U.S. 304 (Supreme Court, 1995)
Hope v. Pelzer
536 U.S. 730 (Supreme Court, 2002)
Brosseau v. Haugen
543 U.S. 194 (Supreme Court, 2004)
Scott v. Harris
550 U.S. 372 (Supreme Court, 2007)
Pearson v. Callahan
555 U.S. 223 (Supreme Court, 2009)
Jones v. Clark
630 F.3d 677 (Seventh Circuit, 2011)
United States v. John Clifton Pichany
687 F.2d 204 (Seventh Circuit, 1982)
Peter M. Roberts v. Sears, Roebuck & Co.
723 F.2d 1324 (Seventh Circuit, 1984)
United States v. Josan Wolf Patino
830 F.2d 1413 (Seventh Circuit, 1987)
United States v. Huddleston
593 F.3d 596 (Seventh Circuit, 2010)
Plumhoff v. Rickard
134 S. Ct. 2012 (Supreme Court, 2014)
William Hawkins v. Rodney Mitchell
756 F.3d 983 (Seventh Circuit, 2014)
Krysta Sutterfield v. City of Milwaukee
751 F.3d 542 (Seventh Circuit, 2014)
Miguel Gutierrez v. Michael Kermon
722 F.3d 1003 (Seventh Circuit, 2013)
Jason Findlay v. Jon Lendermon
722 F.3d 895 (Seventh Circuit, 2013)
Mullenix v. Luna
577 U.S. 7 (Supreme Court, 2015)

Cite This Page — Counsel Stack

Bluebook (online)
Elias Villalobos v. Louis Picicco, Counsel Stack Legal Research, https://law.counselstack.com/opinion/elias-villalobos-v-louis-picicco-ca7-2026.