McGee v. Gomez

CourtDistrict Court, N.D. Illinois
DecidedApril 8, 2025
Docket1:23-cv-01925
StatusUnknown

This text of McGee v. Gomez (McGee v. Gomez) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
McGee v. Gomez, (N.D. Ill. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

NATHANIEL MCGEE, ) ) No. 1:23-CV-01925 Plaintiff, ) ) v. ) ) Judge Edmond E. Chang ANGEL GOMEZ, MELISSA ALTMAYER, ) and CITY OF CHICAGO, ) ) Defendants. )

MEMORANDUM OPINION AND ORDER

Nathaniel McGee was arrested by Chicago police officers Angel Gomez and Melissa Altmayer after being suspected of pulling out a gun and threatening a woman. R. 1, Compl. ¶¶ 5–6, 8, 10–11, 14, 17.1 But McGee argues that the officers lacked probable cause to arrest him. Id. ¶ 23. So he sued Gomez and Altmayer, bring- ing false arrest and malicious prosecution claims against them. Id. at 3–4.2 McGee also brought an indemnification claim against the City of Chicago. Id. at 4–5. The Defendants now move to dismiss for failure to state a claim, asserting that Gomez and Altmayer did have probable cause to arrest McGee. R. 22, Defs.’ Mot. Be- cause the officers had at least arguable probable cause for the arrest, they are entitled to qualified immunity, which is fatal to all of McGee’s claims. So the Defendants’

1Citations to the record are “R.” followed by the docket entry number and, if needed, a page or paragraph number.

2The Court has subject matter jurisdiction over the federal claims pursuant to 28 U.S.C. § 1331. And the Court has supplemental jurisdiction over the state law indemnifica- tion claim pursuant to 28 U.S.C. § 1367. motion to dismiss is granted. For now, the dismissal is without prejudice to give McGee a chance to amend the complaint. I. Complaint Allegations

At the pleading stage, the ordinary rule is to accept the Complaint’s allegations as true. But there is a body-worn camera video recording of some of the underlying events. As explained in more detail in the next section, that means some of the facts are supplied by the video recording. This section sets forth the allegations in the Com- plaint. On March 31, 2021, around 2:00 a.m., Nathaniel McGee was dropped off in the parking lot of his fiancé’s apartment complex. Compl. ¶ 8. McGee alleges that as he walked across the parking lot, Chicago Police officers Angel Gomez and Melissa

Altmayer stopped him, suspecting that he was the perpetrator of an assault that had been reported at the apartment complex. Id. ¶¶ 9–10. McGee says that he immedi- ately disclosed to the officers that he was lawfully carrying a concealed firearm. Id. ¶ 11. The officers then allegedly ordered McGee to get on his knees, and they pro- ceeded to search him. Id. ¶ 12. McGee claims that he peacefully complied. Id. ¶ 13. According to McGee, although he asked the officers to examine his concealed-carry

license, they refused to do so. Id. ¶ 15. Instead, they arrested McGee and took him to the police station. Id. ¶¶ 14, 19. McGee also alleges that the arrest was improper because there is an “audio” recording of the officers admitting that McGee was not the perpetrator of the assault. Id. ¶ 18. McGee says that the officers arrested him despite knowing that he did not commit the crime. Id. ¶ 19. McGee then spent two days in jail. Id. ¶ 20. He claims 2 that he suffered damages from the arrest and detention, including the loss of employ- ment, loss of liberty, emotional distress, and financial expenses. Id. ¶ 21. So McGee brought this lawsuit. He brings a claim for false arrest, 42 U.S.C. § 1983, against

Gomez and Altmayer. Compl. at 4. And he also seems to bring a § 1983 malicious prosecution claim against the two officers. Id. Finally, McGee brings an indemnifica- tion claim against the City of Chicago. Id. at 4–5. II. Legal Standard Under Federal Rule of Civil Procedure 8(a)(2), a complaint generally need only include “a short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). This short and plain statement must “give the de-

fendant fair notice of what the claim is and the grounds upon which it rests.” Twombly, 550 U.S. at 555 (cleaned up).3 The Seventh Circuit has explained that this rule “reflects a liberal notice pleading regime, which is intended to ‘focus litigation on the merits of a claim’ rather than on technicalities that might keep plaintiffs out of court.” Brooks v. Ross, 578 F.3d 574, 580 (7th Cir. 2009) (quoting Swierkiewicz v. Sorema N.A., 534 U.S. 506, 514 (2002)).

“A motion under Rule 12(b)(6) challenges the sufficiency of the complaint to state a claim upon which relief may be granted.” Hallinan v. Fraternal Order of Police of Chi. Lodge No. 7, 570 F.3d 811, 820 (7th Cir. 2009). “[A] complaint must contain

3This opinion uses (cleaned up) to indicate that internal quotation marks, alterations, and citations have been omitted from quotations. See Jack Metzler, Cleaning Up Quotations, 18 Journal of Appellate Practice and Process 143 (2017). 3 sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face.” Iqbal, 556 U.S. at 678 (cleaned up). These allegations “must be enough to raise a right to relief above the speculative level.” Twombly, 550 U.S. at 555. The

allegations that are entitled to the assumption of truth are those that are factual, rather than mere legal conclusions. Iqbal, 556 U.S. at 678–79. III. Analysis Before getting into the merits of McGee’s claims, it is worth explaining why the Court considers Gomez’s and Altmayer’s body-worn camera footage at the plead- ing stage. It is true that courts are typically limited to the four corners of the plead- ings in evaluating a motion to dismiss. Here, however, McGee himself references and

relies on the “audio recording” in his Complaint. Compl. ¶ 18. Also, when the defense relied prominently on the video recordings in moving to dismiss, McGee did not re- spond by arguing that the Court should not rely on the recordings. See R. 31, Pl.’s Resp. Br. Indeed, in his response brief, McGree repeatedly referred to and relied on the footage for various facts. Id. So it is fair game for the Court to rely on the footage at this stage to determine what actually took place in the leadup to, and during,

McGee’s arrest. At the same time, the Court bears in mind that off-camera facts are still limited to the four corners of the Complaint. Moving on to McGee’s claims: Officers Gomez and Altmayer argue that they are entitled to qualified immunity on both the false arrest and malicious prosecution claims. Defs.’ Mot. at 12. Specifically, they contend that the officers are entitled to

4 qualified immunity because they had “arguable probable cause.” Id. That argument succeeds and undermines all of McGee’s claims. In applying qualified immunity to the Fourth Amendment’s probable-cause re-

quirement, an officer is entitled to qualified immunity if arguable probable cause ex- isted to detain the plaintiff. Huff v. Reichert, 744 F.3d 999, 1007 (7th Cir. 2014).

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Related

Swierkiewicz v. Sorema N. A.
534 U.S. 506 (Supreme Court, 2002)
Brooks v. Ross
578 F.3d 574 (Seventh Circuit, 2009)
White v. Pauly
580 U.S. 73 (Supreme Court, 2017)
Huff v. Reichert
744 F.3d 999 (Seventh Circuit, 2014)
Thomas Moorer v. City of Chicago
92 F.4th 715 (Seventh Circuit, 2024)

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