TABATHA WASHINGTON and DONTE HOWARD v. City of Chicago

In the
United States Court of Appeals
For the Seventh Circuit
____________________
No. 22-2467
TABATHA WASHINGTON and DONTE HOWARD ,
Plaintiffs-Appellants,
v.
C ITY OF C HICAGO, et al.,
Defendants-Appellees.
____________________
Appeal from the United States District Court for the
Northern District of Illinois, Eastern Division.
No. 1:20-cv-00442 — Manish S. Shah, Judge.
____________________
A RGUED O CTOBER 24, 2023 — DECIDED A PRIL 15, 2024
____________________
Before R OVNER , WOOD, and HAMILTON , Circuit Judges.
HAMILTON , Circuit Judge. This case presents claims for
unlawful pretrial detention under the Fourth Amendment
and 42 U.S.C. § 1983, along with state-law claims for
malicious prosecution. Plaintiffs Tabatha Washington and
Donte Howard claim that defendants, Chicago Police
Department detectives Vincent Alonzo, Adrian Garcia, and
Demosthenes Balodimas, deliberately misled judges and a
grand jury to secure judicial determinations of probable cause

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2 No. 22-2467
to detain plaintiffs on charges of first-degree murder. After
over a year in custody, Washington and Howard were tried
and acquitted on all charges. They then filed this suit. The
district court granted summary judgment to the defendants,
and plaintiffs have appealed.
Fourth Amendment claims for unlawful pretrial detention
can survive a judicial determination of probable cause. See
generally Manuel v. City of Joliet, 580 U.S. 357 (2017) (Manuel
I). “[P]retrial detention is a ‘seizure’—both before formal legal
process and after—and is justified only on probable cause.”
Lewis v. City of Chicago, 914 F.3d 472, 477 (7th Cir. 2019), citing
Manuel I, 580 U.S. at 366–67. “[I]f the proceeding is tainted—
[such as] by fabricated evidence—and the result is that
probable cause is lacking, then the ensuing pretrial detention
violates the confined person’s Fourth Amendment rights….”
Manuel I, 580 U.S. at 369 n.8.
The existence of probable cause is a defense to both Fourth
Amendment and malicious prosecution claims. Young v. City
of Chicago, 987 F.3d 641, 646 (7th Cir. 2021). Consequently, this
case turns on whether probable cause existed to detain
Washington and Howard in advance of their trials. In civil
litigation like this case, a rebuttable presumption of probable
cause arises after a judicial determination of probable cause.
See Lewis, 914 F.3d at 477. To overcome this presumption,
plaintiffs must show “that the officer who sought the warrant
[1] ‘knowingly or intentionally or with a reckless disregard
for the truth, made false statements to the judicial officer, and
[2] that the false statements were necessary to the judicial
officer’s determination that probable cause existed for the
arrest.’” Whitlock v. Brown, 596 F.3d 406, 410 (7th Cir. 2010)
(alterations omitted), quoting Beauchamp v. City of Noblesville,

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No. 22-2467 3
320 F.3d 733, 742–43 (7th Cir. 2003), citing in turn Franks v.
Delaware, 438 U.S. 154, 155–56 (1978).1
Here, undisputed facts show that plaintiffs cannot rebut
this presumption. Even if we assume plaintiffs’ list of the de-
tectives’ alleged misrepresentations and omissions is correct,
plaintiffs cannot meet the second prong of the test in Beau-
champ: establishing that those false statements or deliberately
misleading omissions were “necessary” to the judicial offic-
ers’ determinations of probable cause. This is so for two inde-
pendent reasons. First, the State’s Attorney’s Office conducted
its own independent fact-gathering before deciding to file
charges. Second, and again, assuming that plaintiffs’ list of
misrepresentations and misleading omissions is correct, the
remaining undisputed facts would still show probable cause
to detain plaintiffs for first-degree murder. Because plaintiffs
cannot overcome the presumption of probable cause that
arises after a judicial determination, we affirm summary judg-
ment for the defendants.
I. Factual and Procedural Background
A. Factual History
In the evening of May 30, 2018, plaintiffs Tabatha
Washington and Donte Howard, along with Washington’s
cousin Carlton White, all engaged in physical altercations
with Kim Edmondson outside Washington’s apartment in
Chicago. When the conflict ended, Edmondson left the area
and walked about half a mile north. There he encountered
three of his friends, Anthony Beard, Khadijah Hill, and Larry
1 Because Beauchamp was the first case in which we set out this two-
prong test, we refer to it as the Beauchamp test in this opinion. See 320 F.3d
at 742–43.

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4 No. 22-2467
Nelson, in a parking lot. Edmondson was shirtless and
bleeding from his lip and chest. He told his friends that he had
been jumped by two men and one or two women with a pole.
He then walked behind a nearby dumpster to urinate. Soon
after that, someone else told Beard, Hill, and Nelson that
Edmondson had collapsed. They walked over and saw him
behind the dumpster lying on his back, not breathing, with
blood pooling around his head. They called 911 and flagged
down nearby police officers, but first responders were unable
to revive Edmondson. He was pronounced dead at the scene.
The medical examiner later concluded that Edmondson died
from blunt-force trauma to the back of the head.
Chicago Police Department detectives Vincent Alonzo,
Adrian Garcia, and Demosthenes Balodimas arrived to inves-
tigate. The three parking-lot witnesses each told them of Ed-
mondson’s wounds to the chest and lip, and they told the de-
tectives Edmondson’s story about being beaten up by several
of his neighbors. One of the parking-lot witnesses knew
where Edmondson had lived and led detectives to the apart-
ment building, about a half-mile away—the same building
where Washington lived.
The detectives canvassed the building to see if anyone
knew about an altercation with Edmondson. Detective
Balodimas later said that, when he was standing outside
Washington’s apartment, he heard her say, “F*** that b**** he
got what he deserved,” and “he ain’t gonna get my gun.”
Balodimas also said he heard White say, “You gotta protect,
you gotta fight.” Plaintiffs dispute all of these assertions. A
detective knocked on the door of Washington’s apartment
and Washington, White, and Howard opened the door. How-
ard at first told the detectives they could not enter without a

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No. 22-2467 5
warrant. The detectives asked if everything was alright, and
Washington told them “there was an altercation earlier, with
some guy that had been evicted from this building.” She also
said, “He was trying to fight me.”
Washington then allowed the detectives to enter her apart-
ment. She and White spoke to detectives in one room while
Howard and another friend, Cynthia Cage, sat on a couch
nearby. White explained that there was an altercation with a
man who had been evicted from the building who “kept com-
ing around trying to fight,” and White was defending himself.
Washington added “he tried to hit me,” saying she hit him to
defend herself. Detective Garcia told the group that they
needed to come to the police station to straighten everything
out. Washington said that Cage had not been involved in the
altercation and that Howard had just gotten there. Howard
told detectives falsely that his name was Jeremiah Johnson
and claimed that he had just arrived at the apartment.
The detectives handcuffed Washington and White, placed
them in separate squad cars, and took them to the police
station for further investigation. Once at the station and just
after midnight on May 31, Detectives Garcia and Alonzo
began separately interrogating Washington and White.
During the various overnight interrogations, White and
Washington recounted a variety of sometimes contradictory
details about their encounter with Edmondson. The district
court’s order granting summary judgment provides a
thorough account of their various explanations during these
interrogations. Washington v. City of Chicago, No. 20-cv-442,
2022 WL 2905669 (N.D. Ill. July 22, 2022).
White told detectives that Edmondson had attacked him a
week earlier and had left a cut on his face. White said the

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6 No. 22-2467
altercation earlier that evening started when Edmondson—
clearly high on cocaine or other drugs—approached him and
Cage and repeatedly called Cage a b****. When White tried to
calm him down, Edmondson swung at him. White ducked the
punch and hit Edmondson once. White eventually indicated
that Washington came out from her apartment with a gray,
non-wooden stick and hit Edmondson “probably three”
times—in the chest, arm, and lip—telling him, “stop playing
with my cousin.”
After being told that Washington had identified a third
man involved in the fight, White ultimately confirmed that
the other man in the fight had been Howard, whom the
detectives had spoken to in Washington’s apartment but who
had given the detectives a false name and falsely said he had
just arrived there. White said that Howard was tussling in the
street with Edmondson but that they were not really fighting.
White repeatedly told detectives that neither Howard nor
Edmondson landed a punch on the other and that
Edmondson left after the fight with Howard. It was then,
according to White, that Washington ran up and hit
Edmondson with the little stick. According to White,
Edmondson then said, “I’ll be back,” and walked away, and
White thought it was over. White was adamant that no one
ever hit Edmondson on the top of the head and that
Edmondson had no head injury when he left the scene of the
altercation.
In separate interrogations the same night, Washington at
first denied having any negative history with Edmondson.
She admitted to hitting Edmondson in the chest with a stick
or a pole after he tried to hit her, and she said White had
stepped in and begun to fight Edmondson. She also admitted

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No. 22-2467 7
that after she had tried to break up the fight between White
and Edmondson, a third man had gotten involved, at first say-
ing that she did not know his identity but ultimately identify-
ing him as plaintiff Howard, the second man in her apartment
earlier that evening. The detectives told her they did not be-
lieve she was physically capable of causing the fatal damage
to Edmondson’s head. Washington eventually told the detec-
tives three times that Howard had struck Edmondson twice
in the head with a pole. She apologized to the detectives for
lying and insisted that she did not know how hard Howard
had hit Edmondson.
Later that morning, May 31, detectives went back to
Washington’s apartment to speak to her friend Cage. Cage
told the detectives that White and Edmondson started
arguing in front of the building and that White punched
Edmondson while the two were arguing. Cage said that
during the altercation between White and Edmondson,
Washington had approached with a pole in her hand and had
hit Edmondson with it several times. Then, Cage continued,
Howard began to fight with Edmondson in the middle of the
street, landing some punches before Edmondson walked
away toward the parking lot where he encountered his
friends Beard, Hill, and Nelson. She said Edmondson was
bleeding from the mouth but otherwise appeared fine when
he left.
Later that same day, a prosecutor from the Cook County
State’s Attorney’s Office, Assistant State’s Attorney Patrick
Waller, began re-interviewing witnesses. ASA Waller
interviewed the parking-lot witnesses (Beard, Hill, and
Nelson) at the police station. The witnesses repeated that
Edmondson had walked up to them with cuts on his chest and

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8 No. 22-2467
lip and said that a couple of guys and a woman jumped him
with a pole or a pipe. Edmondson had then walked off and
collapsed behind a dumpster. Hill also said that she had
observed Edmondson only from the front and did not see any
leaking or dripping blood down his back. None of the three
witnesses told detectives or the state’s attorneys that they saw
Edmondson bleeding from the top or back of his head.
Later that night, ASA Waller then re-interviewed White
and Washington separately. White told ASA Waller that he
had been with Cage, Washington, and Howard, and that
Edmondson had tried to force his way into Washington’s
apartment. That was when Washington had threatened
Edmondson with a pole. Edmondson had backed away but
started to yell and got “into White’s face” before White struck
him. Howard had then approached and started fighting with
Edmondson in the street. Washington had gone into the
house, come out with a little gray aluminum stick, and hit
Edmondson multiple times in the chest, arm, and lip.
Shortly after, ASA Waller reinterviewed Washington. She
told Waller that she had been outside with Cage, White, and
Howard when Edmondson approached and got in her face.
At that point, she said, she found a light metal pole on the
ground and swung it at him three times. She said she struck
Edmondson on the left side of his lip first and then on his
chest after he jumped at her again, but that the third swing
missed because Edmondson had jumped back.
ASA Waller asked Washington about Howard’s involve-
ment. Washington said he and Edmondson had thrown only
a few punches and then Edmondson had left. When Waller
asked whether she, Cage, Howard, and White were discuss-
ing the altercation in the apartment later that night,

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No. 22-2467 9
Washington told Waller that she could not remember specifics
but said everybody had been talking loudly about what had
happened. ASA Waller confronted Washington about her pre-
vious statements about Howard striking Edmondson in the
head with the pole. Washington responded that she had been
talking fast and was scared and nervous. Washington said
that she had not meant to say Howard had hit Edmondson
with the pole. Howard “was hitting him with his fists,” Wash-
ington said, and “that’s why I said I don’t see how his head
got bust[ed].” Washington repeatedly insisted that she had
never hit Edmondson in the head.
Edmondson’s autopsy was performed the morning of
May 31. The medical examiner concluded that the cause of
death was blunt-force trauma to the head. The autopsy
revealed a 1.25-inch by .75-inch laceration on the top, back,
right side of Edmondson’s head; a hole in his skull that was
about one inch by one inch, and fragments of bone within the
brain. Other injuries included lacerations and contusions to
Edmondson’s left lip, an abrasion to his left ear, a laceration
to the center of his chest, and multiple contusions on both
arms. The examiner concluded that Edmondson’s death was
a homicide based on the investigator’s report of assault and
her own examination of Edmondson’s injuries, which were
consistent with an assault. The examiner spoke with
defendant Alonzo about the results of her autopsy.
Washington gave consent to search her apartment to locate
the pole she had used on Edmondson. At her apartment,
Detectives Alonzo and Balodimas recovered four silver metal
poles that appeared to be one inch in diameter, which they
submitted to the Illinois State Police crime lab for processing.
At that point, ASA Waller designated the investigation as

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10 No. 22-2467
continuing and advised another ASA, Laura Ayala-Gonzalez,
of all the information he had learned during his investigation.
B. Procedural History in State Court
The next day, on June 1, ASA Ayala-Gonzalez approved a
first-degree murder charge against Washington. This charge
was the subject of Washington’s pretrial detention hearing. At
the time, Howard had not yet been arrested. The Felony
Minutes form—created and signed by Detective Alonzo for
use in a probable-cause detention hearing and approved by
ASA Ayala-Gonzalez—stated: “The facts briefly stated are as
follows: The defendant, Washington, was arrested after inves-
tigation determined that the victim Kim Edmondson was
struck on and about the head with a metal object several times
by Washington. The victim Edmondson subsequently expired
due to the injuries received.” Detective Alonzo spoke with
ASA Ayala-Gonzalez when she approved the charges for
Washington and rejected charges for White.
At Washington’s hearing on June 2, the Circuit Court of
Cook County denied bail, finding “that the proof is evident
and presumption great that [Washington], along with some
other uncharged co-defendants as of yet, committed the of-
fense.” Immediately after this determination of probable
cause, the prosecutor informed the court that he had amended
the charge to “felony murder based upon [mob] action,”
which is a first-degree murder charge in Illinois. Defense
counsel waived any objection to this change.2
2 The hearing transcript reads “felony murder based upon action” and
the insertion of “mob” is suggested by the defendants here. We believe
this is the most likely reading of the transcript.

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No. 22-2467 11
Howard was taken into custody on June 4. On June 6, ASA
Ayala-Gonzalez approved the first-degree murder charge
against him. At the start of Howard’s pretrial detention
hearing before a Cook County judge on June 7, the complaint
against him was amended to add a violation of probation. In
the remainder of his hearing, the court found probable cause
to detain Howard without bail on both the murder and
probation violation charges until the “murder case” with
Washington was to be heard three weeks later.
On June 28, 2018, Washington and Howard were indicted
by a grand jury for the offenses of felony mob action and first-
degree murder. The grand jury heard testimony from
defendant Detective Alonzo, as well as Washington’s friend
Cage, and the parking-lot witnesses, Nelson, Beard, and Hill.
Washington and Howard were indicted under all three
prongs of Illinois’s first-degree murder statute, including on
a felony murder theory premised on the underlying felony of
mob violence. Over a year later, after a one-day bench trial, a
Cook County judge found Washington and Howard not
guilty on all counts.
C. Federal Proceedings
Washington and Howard then filed this suit against De-
tectives Alonzo, Garcia, and Balodimas, and the City of Chi-
cago for unlawful pretrial detention under the Fourth
Amendment and 42 U.S.C. § 1983 and for malicious prosecu-
tion under Illinois law. The defendants moved for summary
judgment.
The district court began its analysis “with the offenses of
mob action and first-degree murder—the charges brought by
prosecutors and on which the grand jury indicted plaintiffs.”

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12 No. 22-2467
2022 WL 2905669, at *10. The district court considered the
existence of probable cause for pretrial detention premised on
a felony-murder theory with mob violence as the underlying
felony, though plaintiffs had also been indicted on other
theories of first-degree murder. After identifying the elements
of the felony-murder and mob violence offenses, the district
court held that “at the time of plaintiffs’ … detention,
defendants possessed probable cause to believe that plaintiffs
had acted as part of a group that engaged in violence against
Edmondson.” Id. Per the district court, “undisputed facts
demonstrate that, at the time of plaintiffs’ … detention … [i]t
was reasonable, given these facts, for defendants to believe
that plaintiffs had engaged in criminal conduct.” Id. “The facts
known to defendants reasonably suggested that plaintiffs …
were part of a group engaged in physical violence against
Edmondson.” Id. The district court said that this “was enough
to support the … detention of plaintiffs while prosecutors
weighed specific charges.” Id. The court granted summary
judgment to the defendant detectives and the City of Chicago
on all claims and terminated the case. Washington and
Howard filed this appeal.
II. Standard of Review
We review de novo the district court’s grant of summary
judgment. Young v. City of Chicago, 987 F.3d 641, 643 (7th Cir.
2021). Summary judgment is appropriate when “there is no
genuine dispute as to any material fact and the movant is en-
titled to judgment as a matter of law.” Fed. R. Civ. P. 56(a).
“We draw ‘all justifiable inferences’ in the favor of the non-
moving party.” Flexible Steel Lacing Co. v. Conveyor Accessories,
Inc., 955 F.3d 632, 643 (7th Cir. 2020), quoting Anderson v.

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No. 22-2467 13
Liberty Lobby, Inc., 477 U.S. 242, 255 (1986). We have applied
this standard in our account of the facts.
III. Analysis
A. Fourth Amendment: Pretrial Detention Without Probable
Cause
Section 1983 authorizes suits against police officers and
others who violate federal constitutional or statutory rights
while acting under the color of state law. See 42 U.S.C. § 1983.
Plaintiffs’ suit under section 1983 alleges that the City of
Chicago and three of its police detectives violated their Fourth
Amendment rights. To prove a Fourth Amendment violation,
a plaintiff must show first that a seizure occurred, and then, if
so, that the seizure was unreasonable. Carlson v. Bukovic, 621
F.3d 610, 618 (7th Cir. 2010).
“[P]retrial detention is a ‘seizure’—both before formal legal
process and after….” Lewis v. City of Chicago, 914 F.3d 472, 477
(7th Cir. 2019), citing Manuel v. City of Joliet, 580 U.S. 357, 366–
67 (2017) (Manuel I). The Fourth Amendment “establishes ‘the
standards and procedures’ governing pretrial detention” in
criminal cases. Manuel I, 580 U.S. at 360, quoting Gerstein v.
Pugh, 420 U.S. 103, 111 (1975). The standard of reasonableness
required to justify “pretrial detention is probable cause, that
is, official knowledge of ‘facts and circumstances sufficient to
warrant a prudent [person] in believing’ the detainee has
committed a criminal offense.” Williams v. Dart, 967 F.3d 625,
632 (7th Cir. 2020) (alteration in original), quoting Gerstein,
420 U.S. at 111. Plaintiffs Washington and Howard argue that
the defendant detectives violated their Fourth Amendment
right against unreasonable seizures by causing them to be

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14 No. 22-2467
detained before trial without probable cause. See Manuel I,
580 U.S. at 364–69.3
B. The Presumption of Validity for Judicial Determinations of
Probable Cause
Judicial determinations of probable cause are ordinarily
entitled to a presumption of validity, Lewis, 914 F.3d at 477,
and “an indictment is prima facie evidence of probable
cause,” Coleman v. City of Peoria, 925 F.3d 336, 351 (7th Cir.
2019). But this presumption is rebuttable. In Manuel I, the
Supreme Court taught that Fourth Amendment claims
sometimes survive a judicial determination of probable cause.
580 U.S. at 368–69 (plaintiff may seek relief for violations of
Fourth Amendment rights “not merely for his (pre-legal-
process) arrest, but also for his (post-legal process) pretrial
3 In the district court, the parties debated whether, to sustain pretrial
detention, a finding of probable cause must relate to the charged offense,
or whether a generic finding of probable cause to believe the detainee
committed any criminal offense is sufficient. In its order granting sum-
mary judgment, the district court implied that Washington and Howard
could have been lawfully detained in advance of their trial for first-degree
murder and mob action because probable cause existed for other crimes
under the Illinois code, such as battery, aggravated battery, disorderly
conduct, and obstruction. Washington and Howard challenge this portion
of the district court’s ruling, arguing that, because plaintiffs’ probable-
cause hearings had been directed specifically to the charges of murdering
Edmondson, probable cause for pretrial detention could not be premised
on “other hypothetical charges.” On appeal, the defendants seem to have
conceded this point, admitting that pretrial detention required “probable
cause to believe that Washington and Howard killed Edmondson,” and
waiving any argument that probable cause related to any criminal conduct
would have been sufficient. Because we find the undisputed facts support
probable cause for first-degree murder and mob action, we need not de-
cide this issue here.

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No. 22-2467 15
detention.” (footnote omitted)). The Supreme Court
explained:
The Fourth Amendment prohibits government
officials from detaining a person in the absence
of probable cause. That can happen when the
police hold someone without any reason before
the formal onset of a criminal proceeding. But it
also can occur when legal process itself goes
wrong—when, for example, a judge’s probable-
cause determination is predicated solely on a
police officer’s false statements. Then, too, a per-
son is confined without constitutionally ade-
quate justification. Legal process has gone for-
ward, but it has done nothing to satisfy the
Fourth Amendment’s probable-cause require-
ment. And for that reason, it cannot extinguish
the detainee’s Fourth Amendment claim….
Manuel I, 580 U.S. at 367 (citations omitted).
Manuel I “clarified that the constitutional injury arising
from a wrongful pretrial detention rests on the fundamental
Fourth Amendment principle that a pretrial detention is a
‘seizure’—both before formal legal process and after—and is
justified only on probable cause.” Lewis, 914 F.3d at 476–77,
citing Manuel I, 580 U.S. at 366–67. In this sort of claim, “the
constitutional right in question is the ‘right not to be held in
custody without probable cause,’” which gives rise to a
Fourth Amendment claim under section 1983 since “the es-
sential constitutional wrong is the ‘absence of probable cause
that would justify the detention.’” Lewis, 914 F.3d at 479, quot-
ing Manuel v. City of Joliet, 903 F.3d 667, 670 (7th Cir. 2018)
(Manuel II). “Put another way, the initiation of formal legal

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16 No. 22-2467
process ‘did not expunge [plaintiff’s] Fourth Amendment
claim because the process he received failed to establish what
that Amendment makes essential for pretrial detention—
probable cause to believe he committed a crime.’” Lewis, 914
F.3d at 477, citing Manuel I, 580 U.S. at 368–69.
C. Overcoming the Presumption of Validity
Plaintiffs argue they were detained before trial without
probable cause in violation of their Fourth Amendment rights
as set out in Manuel I. 580 U.S. at 366–67. Both plaintiffs re-
ceived judicial determinations of probable cause pursuant to
legal process: Washington and Howard were separately
brought before the Circuit Court of Cook County for bail
hearings. The court found probable cause to detain both with-
out bail. A few weeks later, Washington and Howard were in-
dicted by a grand jury on charges of first-degree murder, in-
cluding a felony-murder theory premised on felony mob ac-
tion. Under Manuel I, these judicial determinations of proba-
ble cause do not automatically bar plaintiffs’ Fourth Amend-
ment claims for wrongful pretrial detention, regardless of
whether the judicial determinations of probable cause were
made in a bail hearing or through an indictment. Manuel I, 580
U.S. at 369 n.8 (“Nothing in the nature of the legal proceeding
establishing probable cause makes a difference for purposes
of the Fourth Amendment….”).
Thus, plaintiffs must overcome the presumption of valid-
ity created by the judicial determinations of probable cause at
their bail hearings and in their indictment. “[T]his presump-
tion is premised on an ‘assumption … that there will be a
truthful showing’ of probable cause.” Whitlock v. Brown, 596
F.3d 406, 410 (7th Cir. 2010) (alteration in original), quoting
Franks v. Delaware, 438 U.S. 154, 164–65 (1978). We have thus

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No. 22-2467 17
held that “the presumption may give way on a showing
[1] that the officer who sought the warrant ‘knowingly or in-
tentionally or with a reckless disregard for the truth, made
false statements to the judicial officer, and [2] that the false
statements were necessary to the judicial officer’s determina-
tion that probable cause existed for the arrest.’” Whitlock, 596
F.3d at 410 (alterations omitted), quoting Beauchamp v. City of
Noblesville, 320 F.3d 733, 742–43 (7th Cir. 2003), citing in turn
Franks, 438 U.S. at 155–56. The second half of the test in Beau-
champ follows logically from the requirement that, “[t]o estab-
lish personal liability in a section 1983 action, the plaintiff
must show that the officer ‘caused the deprivation of a federal
right.’” Ortiz v. City of Chicago, 656 F.3d 523, 539 (7th Cir. 2011),
quoting Luck v. Rovenstine, 168 F.3d 323, 327 (7th Cir. 1999),
quoting in turn Hafer v. Melo, 502 U.S. 21, 25 (1991). We discuss
each prong in turn.
1. Prong One: False Statements Made to Judicial Officer
To satisfy the first prong of Beauchamp, plaintiffs Washing-
ton and Howard argue that the police detectives deliberately
misrepresented certain inculpatory evidence and omitted ex-
culpatory evidence in their communications to the prosecu-
tors, the bail hearing courts, and the grand jury. Plaintiffs
identify the following conduct by defendant detectives as in-
stances of false statements or omissions:
False Statements
(1) oral statements to prosecutors that Washing-
ton hit Edmondson on the “head” when refer-
ring to her blow to his lip;
(2) written statements on the Felony Minutes
form submitted in Washington’s pretrial

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18 No. 22-2467
detention hearing that she struck Edmondson
“on and about the head with a metal object sev-
eral times” and that Edmondson “subsequently
expired due to the injuries received”;
(3) oral statements to prosecutors that either
plaintiff hit Edmondson in the back of the head
with any weapon, causing Edmondson’s fatal
wound in the back of his skull;
(4) statements to judicial officers that Detective
Balodimas overheard incriminating statements,
which plaintiffs claim he unilaterally invented.
Omissions
(1) failure to share with prosecutors or judicial
officers video evidence showing Edmondson
walking half a mile after the altercation;
(2) failure to tell prosecutors that no witness
saw a wound on the back of Edmondson’s head
prior to his fall near the dumpster;
(3) failure to tell prosecutors that White and
Washington had reported that Edmondson was
the aggressor in the altercation, not Washington
or Howard.
We begin with the purported false statements. We are
reviewing a grant of summary judgment to defendants,
which requires us to give plaintiffs the benefit of any genuine
disputes of material fact and any reasonable favorable
inferences, but we do not draw inferences that are supported
by only speculation or conjecture. King v. Hendricks County
Comm’rs, 954 F.3d 981, 984 (7th Cir. 2020). Items (1) and (2),

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No. 22-2467 19
the defendants’ statements to judicial officers and on the
Felony Minutes form that Washington hit Edmondson on the
head, referring to the wound she caused on his lip, might be
true in a technical sense. As one of the defendants reminded
plaintiffs’ counsel in a deposition, “[t]he lip … is part of the
head.” A jury could reasonably deem such statements
intentionally misleading, though, since defendants knew that
Washington admitted to hitting him in the lip while
Edmondson died from blunt-force trauma to the back of his
head. This is especially true of the statements on the Felony
Minutes form, which asserted that Washington’s blows
caused Edmondson’s death.
As to statement (3), the detectives did have an admission
from Washington herself that Howard had hit Edmondson on
the head with a metal pipe, so we do not believe a reasonable
jury could find any statement to that effect was knowingly or
recklessly false. But (4), the incriminating statements purport-
edly overheard by defendant Balodimas, are also disputed
material facts. Because we construe facts in favor of the non-
moving parties on summary judgment, we must assume they
were invented by Balodimas. Thus, for the purposes of sum-
mary judgment, we find that statements (1), (2), and (4) were
false statements made intentionally, knowingly, or with at
least reckless disregard for their truth, satisfying the first
prong of Beauchamp.
We also consider the asserted misleading omissions. As to
omission (1), it remains disputed whether prosecutors had
access, before plaintiffs’ initial bail hearings, to the security
footage of Edmondson walking half a mile after his altercation
with Washington and Howard. On May 31, before the first
bail hearing, defendant Alonzo reviewed footage of

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20 No. 22-2467
Edmondson entering the parking lot and showing no obvious
signs of distress. On June 6, several days after Washington’s
bail hearing but the day before Howard’s bail hearing, Alonzo
also obtained video from Edmondson’s half-mile walking
route between the site of the altercation and the location of the
dumpster. It remains in dispute whether defendants ever
turned these videos over to the State’s Attorney’s Office for
consideration in their charging decisions. We assume for
purposes of summary judgment that defendants did not. The
trial judge relied on these videos in her acquittal, and we
agree that these videos are material and exculpatory. We find
that a reasonable jury could infer that defendants exhibited at
least reckless disregard for the truth in failing to turn over the
parking-lot video. Its exculpatory value was self-evident, and
defendants had access to it well in advance of both plaintiffs’
bail hearings. This omission satisfies the first prong of
Beauchamp.
For omissions (2) and (3), a reasonable jury could not infer
that the omissions were made with intentional, knowing, or
reckless disregard for the truth. The defendants knew that
ASA Waller had independently re-interviewed Washington,
White, and the parking-lot witnesses because a detective sat
in on each of these interviews. In those interviews,
Washington told ASA Waller that Edmondson was the one
who started cursing at her and threatening a physical
confrontation. White told ASA Waller that the confrontation
started when Edmondson tried to force his way into
Washington’s apartment. And each of the parking-lot
witnesses told ASA Waller the location of the wounds they
saw on Edmondson’s body prior to his death, with none
mentioning the back of his head. Consequently, no reasonable
jury could find that defendants’ failure to inform prosecutors

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No. 22-2467 21
that no parking-lot witness saw a wound on the back of
Edmondson’s head, and their failure to report Washington
and White’s statements that Edmondson had been the
aggressor, were done with intentional, knowing, or reckless
disregard for the truth. Omissions (2) and (3) do not satisfy
the first prong of Beauchamp.
In sum, for purposes of summary judgment, we treat state-
ments (1), (2), and (4), as well as omission (1), as false state-
ments made to a judicial officer “knowingly or intentionally
or with a reckless disregard for the truth,” satisfying the first
prong of Beauchamp’s test for overcoming the presumption of
validity of judicial determinations of probable cause. 320 F.3d
at 742. We next assess this bundle of arguable misstatements
and omissions under Beauchamp’s second prong.
2. Prong Two: Misrepresentations Necessary to Judicial
Finding of Probable Cause?
The second prong of Beauchamp requires “that the false
statements were necessary to the judicial officer’s
determination that probable cause existed.” 320 F.3d at 742.
We begin with a threshold issue: what sort of causation is
required between the false statements and the judicial
determination of probable cause to overcome the
presumption of validity? Defendants argue for but-for
causation, grounded in Beauchamp’s use of “necessary” to
describe the causal relationship. Id. Plaintiffs, meanwhile, rely
on Manuel’s use of the word “tainted” to argue for a lesser
standard, which they claim is akin to “proximate cause.”4
4 Plaintiffs do not explain why they think proximate causation, which
is usually defined more narrowly than factual, but-for causation, would
be an easier standard to meet. But we take it that plaintiffs are actually

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22 No. 22-2467
The relevant line in Manuel I says that “if the proceeding
is tainted—as here, by fabricated evidence—and the result is
that probable cause is lacking, then the ensuing pretrial de-
tention violates the confined person’s Fourth Amendment
rights.” Manuel I, 580 U.S. at 369 n.8. When the Supreme
Court’s statement is read in context, it becomes clear that de-
fendants’ but-for standard is the correct one. Even the line ref-
erencing a “tainted” proceeding requires that, as a result of the
taint, “probable cause is lacking.” Id.; see also Burrage v.
United States, 571 U.S. 204, 214 (2014) (calling it a “traditional
background principle[]” of law that “a phrase such as ‘results
from’ imposes a requirement of but-for causation”). This
tracks with our use of “necessary” in Beauchamp. See 320 F.3d
at 742; see also United States v. Hatfield, 591 F.3d 945, 948 (7th
Cir. 2010) (“necessary condition” is another way of naming a
“but-for” cause); Ramos v. City of Chicago, 716 F.3d 1013, 1019
(7th Cir. 2013) (civil plaintiff must show not only that deten-
tion was based on false evidence but also that his “seizure
would lack probable cause without that false evidence”).
Thus, the second prong of Beauchamp requires us to determine
whether the evidence permits a reasonable inference that the
arguably false statements and misleading omissions were col-
lectively a but-for cause of the judicial determinations of prob-
able cause to detain plaintiffs on first-degree murder charges.
In this case, two independent reasons bar a finding of but-
for causation. First, the State’s Attorney’s Office conducted its
arguing for something akin to “substantial factor” causation, which ap-
plies in the “rare” situation where “multiple sufficient causes inde-
pendently, but concurrently, produce a result,” and under which strict
but-for causation is not required. See Burrage v. United States, 571 U.S. 204,
214–15 (2014).

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No. 22-2467 23
own independent fact-gathering before filing charges, rather
than relying on the allegedly misleading statements of the
defendant detectives. Second, “when the lies are taken out
and the exculpatory evidence is added in,” the remaining
undisputed evidence still sufficed to support probable cause.
Rainsberger v. Benner, 913 F.3d 640, 643 (7th Cir. 2019). Each
reason alone would be sufficient to affirm summary
judgment. We discuss each in turn.
a. Independent Investigation by Prosecutors Elimi-
nates But-For Causation
First, plaintiffs fail to overcome the causation problem
posed by prosecutors’ own factual investigation in this case.
Because the State’s Attorney’s Office did an independent in-
vestigation into the facts before approving charges and pre-
senting the case to the bail courts and the grand jury, any mis-
statements and/or omissions by the defendant detectives re-
garding those same facts were not necessary to the judicial
determinations of probable cause.
Plaintiffs admit that ASA Waller, the prosecutor originally
assigned to determine whether charges should be filed, inde-
pendently “spoke to Defendants and re-interviewed wit-
nesses.” Waller re-interviewed Washington and White, as
well as the three parking-lot witnesses, Nelson, Beard, and
Hill. From these interviews, as the district court noted,
[T]he State’s Attorney’s Office knew … that no
one claimed that Washington hit Edmondson
on the top or back of his head or reported seeing
Edmondson bleeding from the top or back of his
head before his collapse. The prosecutor had
access to the medical examiner and all the

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24 No. 22-2467
relevant witnesses and underlying source
material. Waller also knew that Washington had
gone back on her story about Howard hitting
Edmondson in the head with a pole (because
Washington told Waller this).
2022 WL 2905669, at *12. When a different prosecutor, ASA
Ayala-Gonzalez, was assigned to the case, ASA Waller told
her all he had learned from his independent fact-gathering.
ASA Ayala-Gonzalez evaluated that evidence and then ap-
proved charges of first-degree murder against Washington
and Howard. Plaintiffs are correct that there were different
prosecutors at the two bail hearings, but this only makes clear
that the State’s Attorney’s office collectively investigated the
case. We agree with the district court that plaintiffs presented
“no evidence that any defendant duped the State’s Attorney
into seeking pretrial detention or pursuing grand-jury indict-
ments.” 2022 WL 2905669, at *12. Like the district court, we
find that “[t]he only reasonable conclusion to be drawn from
the undisputed evidence is that the State’s Attorney main-
tained control over plaintiffs’ prosecution.” Id.
The independent fact-gathering by the State’s Attorney’s
Office, leading to an independent decision to prosecute plain-
tiffs, rendered superfluous any lies, misleading statements, or
omissions by defendants relating to those independently
gathered facts. See Coleman, 925 F.3d at 351 (overcoming pre-
sumption of probable cause requires “evidence that law en-
forcement obtained the indictment through improper or
fraudulent means”). If plaintiffs believed the prosecutors had
also knowingly or recklessly made false or misleading state-
ments about material evidence, they might have tried to sue
those prosecutors. See Buckley v. Fitzsimmons, 509 U.S. 259,

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No. 22-2467 25
273–74 (1993) (absolute prosecutorial immunity does not ex-
tend to prosecutor acting in an investigatory capacity “before
he has probable cause to have anyone arrested”).
The prosecutor’s independent investigation alone is suffi-
cient reason to affirm summary judgment. It renders the pur-
ported misstatements and omissions by the detective defend-
ants unnecessary to any judicial officer’s determination of
probable cause. Beauchamp, 320 F.3d at 742–43. We address
next a second, independent reason that but-for causation is
lacking between the misstatements and omissions and the ju-
dicial determinations of probable cause.
b. Sufficient Evidence Remained to Support Probable
Cause
Even if the prosecutors had relied exclusively on the police
detectives’ descriptions of events, which we assume included
the misrepresentations and omissions discussed above, there
remained enough uncontested, reliable evidence to support
probable cause as a matter of law. This is a second reason
why, under Beauchamp, the misstatements and omissions
raised by plaintiffs were not a necessary but-for cause of any
judicial officer’s determination of probable cause. This point
supplies an independent ground for affirming summary
judgment.
“Probable cause is a common-sense inquiry requiring only
a probability of criminal activity; it exists whenever … a court
has enough information to warrant a prudent person to be-
lieve,” that, in this case, Washington and Howard killed Ed-
mondson. Young, 987 F.3d at 644, quoting Whitlock, 596 F.3d
at 411; see also Doe v. Gray, 75 F.4th 710, 719 (7th Cir. 2023)
(“The existence of probable cause … depends, in the first

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26 No. 22-2467
instance, on the elements of the predicate criminal offense(s)
as defined by state law.” (alterations in original; internal cita-
tion omitted)). Probable cause “deals with probabilities and
depends on the totality of the circumstances.” Maryland v.
Pringle, 540 U.S. 366, 371 (2003). It “requires only a probability
or substantial chance of criminal activity, not an actual show-
ing of such activity,” so it “is not a high bar.” District of Co-
lumbia v. Wesby, 583 U.S. 48, 57 (2018) (internal quotations
omitted).
Probable cause is “‘assessed objectively’ based on ‘the con-
clusions that the … officer reasonably might have drawn from
the information known to him.’” Young, 987 F.3d at 644, quot-
ing Holmes v. Village of Hoffman Estates, 511 F.3d 673, 679 (7th
Cir. 2007). “In determining whether information submitted to
a judicial officer in support of a warrant application was suf-
ficient to establish probable cause, we look only at what the
officer knew at the time he sought the warrant, not at how
things turned out in hindsight.” Beauchamp, 320 F.3d at 743.
Probable cause existed if, at the time of plaintiffs’ pretrial de-
tention hearings, “the facts and circumstances within [the of-
ficer’s] knowledge and of which he had reasonably trustwor-
thy information were sufficient to warrant a prudent person
in believing that [plaintiffs] had committed the crimes.” Id.
Here, the judicial officers were presented with sufficient
undisputed facts to establish probable cause to believe that
Washington and Howard killed Edmondson. Both plaintiffs
were admittedly in a physical altercation with Edmondson a
short time before he died. Washington admitted that she hit
Edmondson with a metal pole on his chest and his lip.
Detectives located a pole matching the description given by
witnesses in Washington’s apartment. A short time later,

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No. 22-2467 27
Edmondson died from a serious wound to the head. Before he
died, Edmondson told the parking-lot witnesses that he had
been beaten by people who lived in his building, which is
where Washington lived. The detectives had no evidence that
Edmondson encountered any other person who might have
caused his death, which the autopsy determined was due to
blunt-force trauma to Edmondson’s head. And Washington
and Howard had been deceptive and evasive with defendant
detectives upon arrest. Howard gave the detectives a false
name, and Washington initially denied knowing the identity
of the other person involved in the altercation with
Edmondson, even though she knew and later admitted it was
Howard.
Washington did not admit to dealing the fatal blow to the
back of Edmondson’s head, of course, but the detectives were
not required to assume that no such blow took place. Bridewell
v. Eberle, 730 F.3d 672, 676 (7th Cir. 2013) (“Police are entitled
to draw on eyewitness descriptions without being required to
assume that witnesses got every detail right, or that every
omission from a description must establish that the omitted
fact did not occur.”). Far from it. Given Washington’s admit-
ted strike to Edmondson’s face with a pipe, no reasonable jury
could have found it unreasonable for the detectives to infer
that Washington dealt an additional blow to the back of Ed-
mondson’s head with the same weapon. See Williamson v.
Curran, 714 F.3d 432, 441 (7th Cir. 2013) (“When presented
with a credible report of criminal behavior, an officer ‘is under
no constitutional obligation to exclude all suggestions that the
witness or victim is not telling the truth.’”), quoting Reynolds
v. Jamison, 488 F.3d 756, 762 (7th Cir. 2007). This is especially
true where suspects exhibit “evasive and deceptive” behav-
ior, as both Washington and Howard had by lying in their

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28 No. 22-2467
initial interrogations. United States v. Reed, 443 F.3d 600, 603
(7th Cir. 2006).
Plaintiffs make much of the detectives’ statements in
Washington’s interrogation that she “couldn’t have done” the
“damage that was done to [Edmondson’s] head,” and that
they did not believe Washington was “strong enough to do
the damage that [Edmondson] … sustained.” The state was
not required to prove as an element of the charges whether
Washington or Howard dealt the fatal blow; either or both of
them could be convicted under a theory of felony murder.
Second, the interrogators’ statements occurred in an attempt
to lead Washington to reveal the identity of the third person
involved in the altercation. Law enforcement officers are not
bound to be truthful when trying to elicit information, includ-
ing the identities of others involved in the offense. Johnson v.
Pollard, 559 F.3d 746, 754 (7th Cir. 2009) (“The fact that an of-
ficer misrepresents the strength of the evidence against a de-
fendant is insufficient, standing alone” to render a resulting
confession unreliable). Indeed, the detectives’ interrogation
on this point was fruitful. Washington eventually told the de-
tectives that Howard hit Edmondson on the back of the head.
It is true that Washington later retracted this statement
while being questioned by ASA Waller. But neither ASA Wal-
ler nor the detectives were obliged to believe Washington’s
recantation. See Spiegel v. Cortese, 196 F.3d 717, 724 (7th Cir.
1999) (“Many putative defendants protest their innocence,
and it is not the responsibility of law enforcement officials to
test such claims once probable cause has been established.”);
see also Cairel v. Alderden, 821 F.3d 823, 835 (7th Cir. 2016)
(summarizing Sang Ken Kim v. City of Chicago, 858 N.E.2d 569,
578–79 (Ill. App. 2006), as a case “affirming summary

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No. 22-2467 29
judgment because probable cause existed at time of arrest de-
spite later recantation of accusation and allegedly coercive in-
terrogation”).
We recognize that some facts known to detectives at the
time weighed against a conclusion that Washington and
Howard committed the murder. Washington is physically
small in stature, and the pipe recovered from her home was a
lightweight silver pole one inch in diameter originally
thought to be a table leg but later identified as part of a feed-
ing tube machine for her children. None of the parking-lot
witnesses said that they had seen any blood coming from
what must have been a serious wound on the back of Ed-
mondson’s head, even when he turned and walked away
from them. And Edmondson had been able to maintain a con-
versation with those witnesses, describing to them the alter-
cation that had just occurred. There is also security footage
showing Edmondson walking half a mile after his altercation
with the plaintiffs without any visible distress or blood. We
assume for purposes of summary judgment that the detec-
tives had access to that video before plaintiffs’ probable cause
hearings.
These serious factual discrepancies contributed heavily to
plaintiffs’ eventual acquittal, and for good reason. But proba-
ble cause demands much less than proof beyond a reasonable
doubt. United States v. Bullock, 632 F.3d 1004, 1022 (7th Cir.
2011) (probable cause determination “does not require evi-
dence sufficient to support a conviction, nor even evidence
that it is more likely than not that the suspect committed a
crime” (internal citation omitted)). Probable cause existed as
a matter of law even when we give the plaintiffs the benefit of
factual disputes.

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30 No. 22-2467
Plaintiffs rely on other cases finding a lack of probable
cause to support pretrial detention, but they are distinguish-
able. Hurt v. Wise is a post-Manuel I case reversing a grant of
summary judgment on a wrongful pretrial detention claim.
880 F.3d 831 (7th Cir. 2018), overruled on other grounds by
Lewis v. City of Chicago, 914 F.3d 472 (7th Cir. 2019). In Hurt,
the “only source of probable cause” to arrest and detain the
plaintiff was his supposed confession, “so everything turn[ed]
on it.” 880 F.3d at 837 (emphasis in original). But the supposed
confession was “replete with easily verified and contempora-
neous evidence of inaccuracy and unreliability.” Id. “Several
critical ‘facts’ that [plaintiff] offered were facially impossible.
For example, if [plaintiff’s] account of where he and his sib-
lings had dumped [the victim’s] body … was true, the body
would have had to float upstream four to six miles to have ar-
rived at the location where it was found.” Id. (emphasis in
original). This, plus other facts in the confession that were
plainly contradicted by physical or documentary evidence,
led us to conclude that probable cause could not be estab-
lished as a matter of law. Id. at 841–42.
In another post-Manuel I case, Rainsberger v. Benner, we
again found that probable cause could not be resolved as a
matter of law, affirming a denial of qualified immunity on a
standard of review identical to that for summary judgment.
913 F.3d at 643. There, the defendant Officer Benner had filed
a probable cause affidavit for the arrest of plaintiff
Rainsberger on the theory that he murdered his mother, Ruth.
After charges were dropped against Rainsberger, he filed a
section 1983 suit alleging that Officer Benner had lied in his
affidavit. In our analysis, we “eliminate[d] the alleged false
statements, incorporate[d] any allegedly omitted facts, and
then evaluate[d] whether the resulting ‘hypothetical’ affidavit

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No. 22-2467 31
would establish probable cause.” Id. at 647, quoting Betker v.
Gomez, 692 F.3d 854, 862 (7th Cir. 2012). We said that the
remaining “package of facts” supporting probable cause
boiled down to these:
Ruth’s murderer might have been someone she
knew, because the attack was not necessarily
connected to a burglary. Some drawers had
been opened and her purse and medication
were missing; at the same time, there was no
sign of a forced entry, and Ruth’s checkbook,
credit cards, and some cash were still in the
apartment. Rainsberger had a key to her apart-
ment, and cell phone records did not rule out
the possibility that he was in the vicinity of her
apartment complex when the attack happened.
Shortly before he found his mother and called
911, Rainsberger stopped at a Kroger across the
street from his mother’s apartment to buy an
iced tea. He walked in plain view through the
Kroger parking lot carrying a piece of trash,
which he threw away in a receptacle by a
Redbox machine on his way into the store. He
correctly described Ruth’s injury as a blow to
the head, even though he had not removed the
blanket to see the wound. In contrast, the first
responder, who did remove the blanket, ini-
tially thought that Ruth had been shot. Rains-
berger and his two siblings would inherit about
$33,000 apiece if his mother died. When Benner
brought the Rainsberger children to the police
station under false pretenses, Rainsberger and
his brother refused Benner’s request that they

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32 No. 22-2467
take a polygraph test. A week later, they volun-
tarily gave fingerprints and submitted to a DNA
buccal swab.
Rainsberger, 913 F.3d at 648.
Many of these facts, we noted, “would be true of most chil-
dren of aging parents …. These unremarkable facts would be
reason to suspect Rainsberger only if other information cast
them in a suspicious light.” Id. But “[t]he totality of these cir-
cumstances support[ed] nothing more than bare suspi-
cion….” Id. at 649. “If probable cause exists here, then anyone
who experiences the tragedy of discovering a murdered fam-
ily member—and who correctly assesses the cause of the in-
jury and recently threw something away in a public trash
can—can be arrested for murder. Probable cause is a low bar,
but this evidence does not clear it.” Id.
Hurt and Rainsberger look nothing like the bundle of facts
that remain to support probable cause to detain Washington
and Howard, even with the purported “lies stripped and the
omissions added.” Id. at 648. Washington’s admission that
both plaintiffs were involved in a physical altercation with the
victim and had struck him with fists and a metal pole shortly
before he was found dead are hardly “unremarkable facts”
requiring “other information [to] cast them in a suspicious
light.” Id. Nor would a belief that Washington and Howard
killed Edmondson contradict the laws of nature, as in Hurt.
See 880 F.3d at 837. The defendant detectives had no evidence
that anyone else had encountered Edmondson between the
altercation and his death, except for the parking-lot witnesses
who reported open wounds on Edmondson’s face and chest.
Prior to arrest and during initial questioning, Washington and
Howard were evasive and deceptive toward the detectives.

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No. 22-2467 33
And even if the detectives did not believe Washington alone
was capable of dealing the fatal blow, the charged felony-
murder theory did not require that she did.
Consequently, after eliminating the alleged misrepresen-
tations and adding in the omissions, undisputed facts show
that probable cause would have still existed to detain Wash-
ington and Howard pending their trials. No reasonable jury
could conclude otherwise. Thus, even if we assume that the
prosecutors, judges, and grand jury relied on the asserted
false statements and omissions by the defendant detectives,
Washington and Howard cannot show that such false state-
ments were “necessary” to the judicial determinations of
probable cause as required to overcome the presumption of
validity. Beauchamp, 320 F.3d at 742–43. Consequently, the ju-
dicial determinations of probable cause are presumed to be
valid, and the pretrial detention of Washington and Howard
did not violate the Fourth Amendment. Manuel I, 580 U.S. at
367.
D. Malicious Prosecution Claim
Plaintiffs’ claims for malicious prosecution fail for the
same reason that their Fourth Amendment claims fail—the
detectives and courts had probable cause to detain them. See
Young, 987 F.3d at 646, citing Martinez v. City of Chicago, 900
F.3d 838, 849 (7th Cir. 2018) (“To state a claim for malicious
prosecution under Illinois law, a plaintiff must allege that: (1)
he was subjected to judicial proceedings; (2) for which there
was no probable cause….”). Because plaintiffs’ pretrial
detention was supported by probable cause based on the
prosecutors’ independent fact-gathering and even if the
purported lies and omissions are accepted as true, the district

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34 No. 22-2467
court properly granted summary judgment on their malicious
prosecution claims.
The district court’s grant of summary judgment to
defendants is AFFIRMED.

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