Teague v. Armstead

82 F. Supp. 3d 817, 2015 U.S. Dist. LEXIS 29219, 2015 WL 1088106
CourtDistrict Court, N.D. Illinois
DecidedMarch 10, 2015
Docket11-cv-0042
StatusPublished
Cited by3 cases

This text of 82 F. Supp. 3d 817 (Teague v. Armstead) 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
Teague v. Armstead, 82 F. Supp. 3d 817, 2015 U.S. Dist. LEXIS 29219, 2015 WL 1088106 (N.D. Ill. 2015).

Opinion

MEMORANDUM OPINION AND ORDER

JOHN Z. LEE, United States District Judge

This dispute arises out of an alleged confrontation between Plaintiff Marquincy [820]*820Teague and Defendant Chicago Police Officer Travis Armstead in the lock-up area of a ■ Chicago police station. According to Teague, he was standing in the lock-up area when Officer Armstead struck him from behind without provocation, causing Teague to hit his head on the floor and black out. After Teague woke up, he was handcuffed and transported to the hospital by two other officers, where he received medical care, including stitches. Officer Armstead, however, recalled a very different set of events. According to him, Teag-ue assaulted him while Armstead was trying to search Teague in the lock-up area and hit his head as Armstead was trying to subdue him. In the end, Teague was convicted in Illinois state court for assaulting a police officer as a result of the incident.

Undeterred, Teague filed suit against Armstead, the Chicago Police Department (“CPD”), and the City of Chicago in this Court, seeking damages under 42 U.S.C. § 1983 for excessive use of force. Teague also contends that CPD and the City failed in their duty to preserve video recordings that were material to this legal action, thereby committing negligent spoliation of evidence under Illinois law.

Defendants move for summary judgment, arguing that Teague’s excessive force claim is barred under Heck v. Humphrey, 512 U.S. 477, 114 S.Ct. 2364, 129 L.Ed.2d 383 (1994), because success on that claim would necessarily invalidate Teague’s state court conviction. Defendants also maintain that Officer Armstead is entitled to qualified immunity because the undisputed facts show no constitutional violation occurred. Defendants lastly urge the Court to decline to exercise supplemental jurisdiction over Teague’s state law claim.

For his part, Teague argues that Heck does not bar his claims and outlines three factual scenarios in support of his excessive force claim, which he contends would not necessarily invalidate his state court conviction. Teague also argues that qualified immunity is unavailable to Officer Armstead, that the negligent spoliation claim should be allowed to proceed, and that the destruction of evidence creates an adverse inference against Defendants requiring this case to go to trial. For the reasons provided herein, the Court grants Defendants’ motion for summary judgment.

I. Factual Background1

A. Incident in the Seventh District Station Lock-Up Area

On August 20, 2009, the CPD took Teag-ue into. custody following a report of a domestic disturbance at Teague’s home. Defs.’ Am. LR 56.1(a)(3) Stmt. ¶ 6. CPD Officers brought Teague to the Seventh District Station for processing and, during processing, Teague was moved to an area of the station known as the “lock-up.” Id. ¶¶ 7-8. While Teague was being processed, Officer Armstead was in charge of the lock-up area. Id. ¶ 9.

The facts of this case center on a confrontation between Officer Armstead and Teague in the lock-up area. The parties agree that, sometime while Teague was in the lock-up area, Teague and Officer Arm-stead had a confrontation, Teague was knocked unconscious, awoke with a cut on his head, and was taken to the hospital. Id. ¶ 11; PL’s LR 56.1(b)(3)(B) Stmt. ¶ 10. As to the rest, however, the parties’ positions diverge.

In their motion, Defendants argue that Teague has no personal, first-hand knowledge of what caused him to lose consciousness. Defs.’ Am. LR 56.1(a)(3) Stmt. ¶ 11. Teague responds that he does possess first-hand knowledge of being struck from [821]*821behind, but admits he lacks knowledge of who hit him and with what. See PL’s LR 56.1(b)(3)(B) Stmt. ¶ 11. Defendants further assert Teague only identified Officer Armstead as the assailant based on Officer Armstead’s testimony during Teague’s criminal trial. Defs.’ Am. LR 56.1(a)(3) Stmt. ¶ 12. On the other hand, Teague maintains that he identified Officer Arm-stead as his assailant based on comments he overheard in the lock-up area after his return from the hospital. In particular, Teague overheard other individuals commenting that Officer Armstead “kicked [Teague’s] ass.” See Pl.’s LR 56.1(b)(3)(B) Stmt. ¶ 11. Teague also contends that, when he returned to the police station from the hospital, he overheard individuals arguing with Officer Armstead about hitting Teague, and at least one person telling Officer Armstead that he should have killed Teague because now Officer Arm-stead was “going to have a problem.” See PL’s LR 56.1(b)(3)(C) Stmt. ¶¶26-27.2 Both sides admit there were no other witnesses present during the confrontation between Officer Armstead and Teague. See PL’s LR 56.1(b)(3)(C) Stmt. ¶ 5; Defs.’ Reply PL’s LR 56.1(b)(3)(C) Stmt. ¶ 5.

B. The Criminal Trial

After the confrontation, Teague was charged with aggravated battery to a police officer. Defs.’ Am. LR 56.1(a)(3) Stmt. ¶ 13. A criminal bench trial was held on September 28, 2010, and Teague was found guilty of two counts of aggravated battery against a police officer. Id.

At the bench trial, Officer Armstead testified that, around 5:25 a.m., he attempted to search Teague while Teague was in the lock-up holding cell. Id. ¶ 14. Teague was not wearing handcuffs at the time. Id. Officer Armstead noticed that Teague appeared to be under the influence of alcohol with reddish eyes. Id. Teague told Officer Armstead he “wasn’t gonna be able to search him.” Id. Teague then grabbed Officer Armstead’s wrist, sat down on a bench, braced himself, and kicked Officer Armstead, inflicting a “glancing blow.” Id. To defend himself, Officer Armstead asserted, he struck Teague with an open-hand blow, using a technique that was approved by the police department and for which he had received official training. Id. ¶ 15. Officer Armstead then initiated a take-down of Teague, during which time Teague struck his head. Id. During the criminal trial, the parties stipulated that Teague was treated at the hospital that day for blunt head trauma and received six stitches to fix a single laceration to his forehead. Id. ¶ 16.

The court found that Officer Armstead’s testimony was non-evasive; the evidence supported a finding that Officer Armstead was engaged in his official duties; Arm-stead had subdued Teague using physical force as approved by the police department; and Teague’s actions caused physical contact of an insulting nature and bodily harm to Officer Armstead. Id. ¶ 17. Teague appealed the guilty finding to the Appellate Court of Illinois, First District. Id. ¶ 18. The Appellate Court upheld the trial court’s ruling. Id.

C. Plaintiffs Version

Teague does not dispute that Officer Armstead testified in this manner at the trial.y See generally PL’s LR 56.1(b)(3)(B) Stmt. ¶¶ 14-18. Instead, Teague contends that an altogether different confrontation occurred outside of the lock-up area holding cell. See generally id. According to Teague, he was hit from behind without provocation while he was being processed. See

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Cite This Page — Counsel Stack

Bluebook (online)
82 F. Supp. 3d 817, 2015 U.S. Dist. LEXIS 29219, 2015 WL 1088106, Counsel Stack Legal Research, https://law.counselstack.com/opinion/teague-v-armstead-ilnd-2015.