Edwards v. Jolliff-Blake 7thCIR 1NOV2018

Edwards v. Jolliff-Blake 7thCIR 1NOV2018

Chicago PD obtained a search warrant based primarily on the information from a confidential informant. When they executed the search warrant for drugs in the home of Nelson Edwards … they found nothing.  Edwards then sued the officers in a 42 USC 1983 civil suit claiming his Fourth Amendment rights were violated by 1) obtaining a warrant unsupported by probable cause, 2) performing an unreasonable search of their home, and 3) using excessive force during the search.

The court held that 1) there was no dispute of material fact regarding the probable cause determination 2) that the execution of the warrant done in a reasonable manner, and 3) regardless of the decision in 1 and 2, the officer were entitled to qualified immunity because  an “officer who relies on a subsequently invalidated warrant may be liable for § 1983 damages only if the warrant application was ‘so lacking in indicia of probable cause as to render official belief in its existence unreasonable.’  The Seventh Circuit held that the district court correctly concluded the search warrant was supported by probable cause and the officers’ conduct in executing the warrant was reasonable and therefore affirmed the decision.

To read or download the full decision CLICK HERE