John A. Trakselis v. Village of Justice

United States Court of Appeals
For the Seventh Circuit
Chicago, Illinois 60604
Submitted September 2, 2025*
Decided September 2, 2025
Before
FRANK H. EASTERBROOK, Circuit Judge
THOMAS L. KIRSCH II, Circuit Judge
DORIS L. PRYOR, Circuit Judge
No. 24-3282
JOHN A. TRAKSELIS,
Plaintiff-Appellant,
v.
VILLAGE OF JUSTICE, et al.,
Defendants-Appellees.
Appeal from the United States District
Court for the Northern District of
Illinois, Eastern Division.
No. 20 CV 936
Georgia N. Alexakis,
Judge.
O R D E R
Police officers in Justice, Illinois, arrested John Trakselis for driving after his
Illinois privileges had been revoked for past offenses. New charges were filed but later
dismissed. Invoking federal and state law, Trakselis sued the officers and the Village of
* We have agreed to decide the case without oral argument because the briefs and
record adequately present the facts and legal arguments, and oral argument would not
significantly aid the court. F ED. R. A PP . P. 34(a)(2)(C).
NONPRECEDENTIAL DISPOSITION
To be cited only in accordance with F ED. R. APP . P. 32.1

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Justice. The district court entered summary judgment for the defendants, concluding
that the officers had probable cause to believe Trakselis had no privilege to drive in
Illinois, and that this defeated Trakselis’s claims. We affirm.
We construe the undisputed facts and draw reasonable inferences in favor of
Trakselis, the nonmoving party. Petersen v. Pedersen, 140 F.4th 421, 423, 426 (7th Cir.
2025). One morning in 2018, Officer Joseph Pavlik spotted and recognized Trakselis
driving a van, recalled that his Illinois license had been revoked, and so pulled the van
over. Pavlik called out, “Hey John, put your hands out the window, man,” handcuffed
Trakselis, and placed him in the back of a squad car. Officer Ronald Ward arrived to
assist Pavlik and to have the van towed.
Whether Pavlik used a squad-car computer to confirm Trakselis’s driver status
immediately before the stop is contested. Pavlik testified to that effect at a probable-
cause hearing on state charges, but Trakselis stresses the absence of corroborating
computer records. Regardless, within minutes after the encounter began, a dispatcher
spoke with Pavlik and pulled up a report that Trakselis’s Illinois driving privileges had
last been revoked in 2015. The report also mentioned a more recent Indiana license. But
after an Illinois revocation, it is illegal to drive in the state—even with an out-of-state
license—until privileges are restored. 625 ILCS 5/6-210.
At the probable-cause hearing, Pavlik testified that before any electronic record
check, he recognized Trakselis from “prior contact” and knew his Illinois license had
been revoked. On cross-examination by Trakselis’s criminal attorney, Pavlik could not
recall dates or the precise nature of the prior contact but estimated an encounter
“[m]aybe a couple months” before this stop. The court found probable cause to charge
Trakselis under 625 ILCS 5/6-303(a), although the State later dropped the charge.
Trakselis then sued the Village, Pavlik, and Ward. But Pavlik died, and the
district court substituted Susanne Skjerseth as the special representative of his estate.
Against the officers, Trakselis asserted constitutional claims under 42 U.S.C. § 1983 for
false arrest and unreasonable seizure of property. Against the Village and officers alike,
he pressed Illinois claims for false imprisonment and malicious prosecution.
At summary judgment, Trakselis’s then-attorney contested Pavlik’s “purported
knowledge” of his Illinois driving privileges. Yet the thrust was not that Pavlik did not
remember past suspensions, revocations, and more recent encounters. Instead, citing
Indiana driver records, Trakselis suggested that his Indiana license (or some
unspecified fact) undermined his “actual revocation status.” Contra 625 ILCS 5/6-210.

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No. 24-3282 Page 3
The district court, opining that the case “begins and ends” with probable cause,
entered summary judgment for the defendants. Because officers had probable cause to
think Trakselis was driving in Illinois while his privilege to do so remained revoked, no
defendant violated any right or duty by arresting him, seizing his van, and launching a
prosecution. The court rejected Trakselis’s theory that his Indiana license required
officers to presume he could drive in Illinois. Exercising supplemental jurisdiction
under 28 U.S.C. § 1367, the court denied the state-law claims alongside the federal ones.
On appeal, Trakselis does not deny that probable cause would defeat his claims.
What he denies is that officers had probable cause. He first questions whether Pavlik’s
recounted memory of “prior contact” was clear and specific enough to yield reasonable
grounds to believe Trakselis remained unauthorized to drive. Cf. United States v. Hope,
906 F.2d 254, 258 (7th Cir. 1990) (identifying probable cause based on officer’s specific
memory of driver-status check a week or so before arrest); United States v. Hobbs,
509 F.3d 353, 361 (7th Cir. 2007) (recognizing probable cause based on officer’s general
testimony that he “discovered” suspension “sometime prior” to arrest). Trakselis now
says summary judgment was improper because Pavlik’s memory was vague and
doubtful. But in response to the motion for summary judgment, Trakselis did not alert
the court or opposing counsel to this type of dispute. Instead, he seemed to suggest that
whatever Pavlik remembered, the Indiana license meant Trakselis was in fact
authorized to drive. Trakselis cannot now present a new species of dispute for the first
time on appeal. See Burton v. Bd. of Regents of Univ. of Wis. Sys., 851 F.3d 690, 695–96
(7th Cir. 2017).
Next, Trakselis argues that once Pavlik learned of the Indiana license, any
probable cause evaporated, the encounter should have stopped, and charges became
improper. Perhaps the Indiana license would complicate a criminal trial; Trakselis says
that under interstate agreements, Indiana would not have issued a license if Illinois had
reported a still-valid revocation. But doubts and conflicting evidence that might
complicate a trial do not defeat probable cause if officers had reason to err on the side of
believing a crime was committed. Coleman v. City of Peoria, 925 F.3d 336, 351 (7th Cir.
2019) (given “sound reason to believe the suspect committed a crime,” police “may
arrest and allow the criminal justice system to determine guilt or innocence”); Deng v.
Sears, Roebuck & Co., 552 F.3d 574, 577 (7th Cir. 2009) (“ability to explain away
seemingly damning facts does not negate … probable cause, even though it might
provide a good defense should the case go to trial”); Askew v. City of Chicago, 440 F.3d
894, 896 (7th Cir. 2006) (Constitution permits police “to initiate the criminal process and
leave the sifting of competing claims and inferences to detectives, prosecutors, judges,

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and juries in the criminal prosecution”). No defendant was required to assume, before
pretrial proceedings ramped up, that Trakselis’s Indiana license barred prosecution.
See 625 ILCS 5/6-210.
Last, Trakselis seeks to attack Pavlik’s credibility. He reasons that jurors who
perceived a lack of corroborating detail could disbelieve Pavlik’s otherwise-
uncontroverted testimony on his personal knowledge that Trakselis’s driving privileges
had been revoked. But “[t]he mere prospect of challenging a witness’s credibility in this
manner is not enough, standing alone, to avoid summary judgment.” Outlaw v. Newkirk,
259 F.3d 833, 841 (7th Cir. 2001); see Est. of Logan v. City of South Bend, 50 F.4th 614, 615
(7th Cir. 2022) (reasoning similarly).
Because the summary-judgment record established that probable cause
supported Trakselis’s arrest, detention, and prosecution (and the towing of his van), the
district court properly entered judgment against him. We thus need not address the
defendants’ alternative defenses.
AFFIRMED

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