Nichols v. Hulsey

CourtDistrict Court, S.D. Illinois
DecidedJanuary 30, 2020
Docket3:19-cv-01151
StatusUnknown

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

Bluebook
Nichols v. Hulsey, (S.D. Ill. 2020).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS

LEE E. NICHOLS, #13801-025, ) ) Plaintiff, ) ) vs. ) Case No. 19-cv-01151-JPG ) PATRICK HULSEY ) and KEVIN SMITH, ) ) Defendants. )

MEMORANDUM & ORDER GILBERT, District Judge: Plaintiff Lee Nichols, an inmate in the custody of the Federal Bureau of Prisons (“BOP”) who is currently incarcerated at the Beckley Federal Correctional Institution (“FCI-Beckley”), brings this action pursuant to Bivens v. Six Unknown Fed’l Narcotics Agents, 403 U.S. 388 (1971), for constitutional deprivations that resulted from his arrest without a warrant in Monroe County, Illinois, on July 15, 2017. (Doc. 1). He seeks unspecified relief against Dupo Police Department Chief of Police Kevin Smith and Dupo Officer Patrick Hulsey. (Id. at p. 6). The Complaint is now before the Court for preliminary review under 28 U.S.C. § 1915A, which requires the Court to screen prisoner complaints and filter out non-meritorious claims. 28 U.S.C. § 1915A(a). Any portion of a complaint that is legally frivolous or malicious, fails to state a claim for relief, or requests money damages from an immune defendant must be dismissed. 28 U.S.C. § 1915A(b). At this juncture, the factual allegations are liberally construed. Rodriguez v. Plymouth Ambulance Serv., 577 F.3d 816, 821 (7th Cir. 2009). The Complaint Plaintiff makes the following allegations in the Complaint: On or around July 15, 2017, Plaintiff was arrested in Monroe County, Illinois. (Doc. 1, p. 7). Officer Patrick Hulsey spotted Plaintiff in a bar while he was off duty. (Id.). The officer contacted Chief of Police Kevin Smith and requested authority to arrest Plaintiff on “outstanding warrants.” (Id.). At the time, Plaintiff

claims that there were no outstanding warrants for his arrest. The warrants were issued in St. Clair County two days after his arrest for aggravated fleeing of police that occurred three weeks earlier on June 22, 2017. At the time of the aggravated fleeing incident, however, Officer Hulsey was unable to obtain a warrant for Plaintiff’s arrest. On July 15, 2017, the same officer arrested Plaintiff while Officer Hulsey was off duty, outside of his jurisdiction, and without a warrant. During the arrest, the officer seized a cell phone, $391, and a 2005 Harley Davidson. (Id.). Plaintiff claims that this arrest is unrelated to his present incarceration. (Id. at p. 4). Based on the allegations, the Court finds it convenient to organize the pro se Complaint into the following enumerated Counts:

Count 1: Fourth Amendment claim against Defendants for the unlawful arrest of Plaintiff on July 15, 2017.

Count 2: Fourth Amendment claim against Defendants for the unlawful seizure of a cell phone, cash, and Harley-Davidson incident to Plaintiff’s arrest on July 15, 2017.

Any claim that is mentioned in the Complaint but not addressed herein is considered dismissed without prejudice as inadequately pled under Twombly.1

1 See Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007). Discussion A. Bivens or Section 1983 Although Plaintiff is currently a federal inmate at FCI-Beckley, his claims are not governed by Bivens which provides a remedy for certain constitutional rights violations by federal officials. Bivens, 403 U.S. 388 (1971). Plaintiff brings his claims against local officials who were acting

under color of state law at the time of his arrest. Such claims generally fall under 42 U.S.C. § 1983, which imposes liability on state and local employees for violations of federal rights. See Belbachir v. County of McHenry, 726 F.3d 975, 978 (7th Cir. 2013). In the Complaint, Plaintiff does not assert that either defendant acted under color of federal authority when making his arrest. (Doc. 1, p. 7). He explicitly states that this suit is unrelated to his federal imprisonment. (Id. at p. 3). He sues local officials for arresting him without a warrant and seizing certain property from him. This case arises under Section 1983. B. Counts 1 and 2 A Fourth Amendment false arrest claim arises when an arrest is made without a warrant

and without probable cause. Bianchi v. McQueen, 818 F.3d 309, 321 (7th Cir. 2016) (citing Wallace v. Kato, 549 U.S. 384, 389 (2007)). Plaintiff claims that his arrest was made without a warrant, and the allegations suggest that the arrest was also made without probable cause. Plaintiff asserts that he was arrested by an off-duty officer who was operating outside of his jurisdiction at the time of the arrest. In Illinois, a police officer “can make an extraterritorial warrantless arrest in the same situation that any citizen can make an arrest.” People v. Niedzwiedz, 268 Ill. App. 3d 119 (1994) (citing 725 ILCS 5/107-3, stating “[a]ny person may arrest another when he has reasonable grounds to believe that an offense other than an ordinance violation is being committed.”). However, an officer exceeds the scope of his authority to make a citizen’s arrest when he uses the powers of his office to gather evidence that is not available to a private citizen outside his jurisdiction. Id. (citing People v. Lahr, 147 Ill. 2d 379 (1992) (off-duty police officer may not arrest someone using a radar gun)). The allegations suggest that Officer Hulsey did just that when he arrested Plaintiff using information that he gathered from Dupo Chief of Police Smith that was not otherwise available to a private citizen outside of his jurisdiction. Because both

defendants were allegedly involved in Plaintiff’s arrest, the Court cannot dismiss Count 1 against either one. Whether the related seizure of property was reasonable remains to be seen. See Soldal v. Cook County, 506 U.S. 56, 71 (1992) (“[t]he standard for whether a seizure survives constitutional scrutiny is reasonableness, not merely whether officers had a warrant.”). At this point, Count 2 shall also receive further review against both defendants. Disposition IT IS ORDERED that the Complaint (Doc. 1) survives preliminary review under 28 U.S.C. § 1915A. COUNTS 1 and 2 will receive further review against Defendants KEVIN SMITH and PATRICK HULSEY. Pursuant to Administrative Order No. 244, Defendants

need only respond to the issues stated in this Merits Review Order. The Clerk of Court shall prepare for Defendants KEVIN SMITH and PATRICK HULSEY: (1) Form 5 (Notice of a Lawsuit and Request to Waive Service of a Summons), and (2) Form 6 (Waiver of Service of Summons). The Clerk is DIRECTED to mail these forms, a copy of the Complaint (Doc. 1), and this Memorandum and Order to each defendant’s place of employment as identified by Plaintiff.

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

Related

Soldal v. Cook County
506 U.S. 56 (Supreme Court, 1992)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Wallace v. Kato
127 S. Ct. 1091 (Supreme Court, 2007)
Rodriguez v. Plymouth Ambulance Service
577 F.3d 816 (Seventh Circuit, 2009)
People v. Niedzwiedz
644 N.E.2d 53 (Appellate Court of Illinois, 1994)
People v. Lahr
589 N.E.2d 539 (Illinois Supreme Court, 1992)
Louis Bianchi v. Thomas McQueen
818 F.3d 309 (Seventh Circuit, 2016)
Belbachir v. County of McHenry
726 F.3d 975 (Seventh Circuit, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
Nichols v. Hulsey, Counsel Stack Legal Research, https://law.counselstack.com/opinion/nichols-v-hulsey-ilsd-2020.