Rakeem Harris v. Chris Renken

United States Court of Appeals
For the Seventh Circuit
Chicago, Illinois 60604
Submitted May 19, 2026*
Decided June 1, 2026
Before
DAVID F. HAMILTON, Circuit Judge
JOHN Z. LEE, Circuit Judge
JOSHUA P. KOLAR, Circuit Judge
No. 25-2053
RAKEEM HARRIS,
Plaintiff-Appellant,
v.
CHRIS RENKEN, et al.,
Defendants-Appellees.
Appeal from the United States District
Court for the Central District of Illinois.
No. 1:23-cv-01213-JEH-RLH
Jonathan E. Hawley,
Judge.
O R D E R
Rakeem Harris appeals the district court’s summary judgment rejecting his claim
that two court security officers unreasonably detained him in violation of his Fourth
Amendment rights. See 42 U.S.C. § 1983. We affirm.
* 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NONPRECEDENTIAL DISPOSITION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

-- 1 of 4 --

No. 25-2053 Page 2
I.
A security camera captured many of the events at issue. Although the parties
disagree how to frame what the video shows, we construe the facts in the light most
favorable to Harris because his version of events is not “utterly discredit[ed]” by the
video. See Pam v. City of Evansville, 154 F.4th 523, 528–29 (7th Cir. 2025) (quoting Gant v.
Hartman, 924 F.3d 445, 450 (7th Cir. 2019)).
One late afternoon in May 2022, two security officers at the McLean County
Courthouse, Chris Renken and Nathan Haynes, were on the lookout for a man named
Michael Anderson. For reasons not explained in the record, Renken and Haynes had
been commanded to serve him with a protective order. The officers were provided a
grainy photo of Anderson taken in September 2021. The photo showed a Black man
with shoulder-length dreadlocks. The officers were told that Anderson was in his early
thirties and was supposed to stop by the courthouse “late in the day.”
Around 4:30 PM, Harris walked into the courthouse to submit paperwork to the
clerk’s office. Harris is a Black man in his early thirties, of similar height to Anderson,
with braided hair down to his chest. Suspecting that Harris was Anderson, Renken and
Haynes approached him to serve him with the protective order.
Harris alleges that the officers seized him during the five minutes he spent in the
courthouse. During an initial encounter, the officers approached him, referred to him as
“Michael Anderson,” and asked for identification. Harris says he told them he was not
Anderson, and he walked away.
Soon thereafter, the officers followed him to a courthouse elevator. After he
entered the elevator, the officers blocked the doors from closing and again asked Harris
to identify himself. The video shows that three seconds after Harris entered the
elevator, he ducked past the officers and left the elevator. Moments later, Harris and the
officers spoke in a hallway. The officers, each a few feet away from Harris, asked for
identification, told him he was detained, and threatened to arrest him for “obstruction
of service.” After some back-and-forth, the officers told Harris he could leave. But
immediately afterwards, the officers tailed Harris as he went into a nearby stairwell.
Harris re-emerged from the stairwell seconds later. The video does not show what
happened in the stairwell, but Harris attested that Renken “tug[ged]” Harris’s arm to
keep him from making his way upstairs.

-- 2 of 4 --

No. 25-2053 Page 3
Harris then returned to the courthouse lobby. He and the officers had a back-
and-forth for several minutes before he alone went upstairs, completed his business,
and left the courthouse.
Weeks later, Harris sued Renken and Haynes for violating state laws and his
Fourth Amendment rights. He also named other officers as defendants for their part in
unrelated events. The claims against other officers were dismissed at screening,
see 28 U.S.C. §1915(e)(2), and Harris’s state law claims against Renken and Haynes were
dismissed upon the defendants’ motion. Harris does not challenge the dismissal of
those claims on appeal, so we discuss them no further.
Both parties moved for summary judgment on Harris’s Fourth Amendment
claim. The district court granted the defendants’ motion and denied Harris’s. No
reasonable jury could find that Harris had been seized, the court concluded, because the
officers’ questions did not restrain Harris’s liberty and he moved freely about the
courthouse. And even if he had been seized, no jury could find that the seizure was
unreasonable because, under state law, his refusal to identify himself was a crime.
See Migliore v. County of Winnebago, 321 N.E.2d 476, 479 (Ill. App. Ct. 1974) (one
obstructs justice by refusing to identify oneself to officers serving process); Williams v.
Jaglowski, 269 F.3d 778, 782 (7th Cir. 2001) (discussing Illinois’s identification laws and
Migliore).
II.
To defeat the defendants’ motion for summary judgment, Harris needed to
provide evidence from which a jury could find that that his encounter with the officers
(1) qualified as a seizure, and (2) was unreasonable. See Moderson v. City of Neenah,
137 F.4th 611, 614–15 (7th Cir. 2025). We review de novo whether Harris met that
standard. Id. at 614.
Harris takes issue with the district court’s conclusion that his refusal to identify
himself justified the officers’ actions. He points us to Brown v. Texas, 443 U.S. 47 (1979),
where the Supreme Court held that refusing to identify oneself in violation of state law
cannot justify a detention if the initial seizure was unlawful. Id. at 51–52. And in
Harris’s view, that sequence is what happened here: the officers approached him and
questioned him before he refused to identify himself, and they did so without reasonable
suspicion of a crime. (He does not contest that state law required him to identify
himself.)

-- 3 of 4 --

No. 25-2053 Page 4
Implicit in Harris’s argument, however, is the misconception that the officers’
initial approach was a seizure. A seizure occurs only when, under the circumstances, a
reasonable person would not feel free to leave. United States v. Holly, 940 F.3d 995, 1000
(7th Cir. 2019). Relevant considerations include the officers’ language and tone, show of
physical force, accusations of a crime, or demands to stay put. See id. But here, when the
officers first walked towards Harris, they did none of those things. They merely asked
him to identify himself as they were compelled to do by court order and statute. As the
district court explained, asking questions of someone is not a seizure, Florida v. Royer,
460 U.S. 491, 497 (1983), and neither is requesting identification. Hiibel v. Sixth Jud. Dist.
Ct. of Nev., 542 U.S. 177, 185 (2004). Because no jury could find that Harris was seized
before he refused to identify himself, there is no triable issue under the Fourth
Amendment. See United States v. Broomfield, 417 F.3d 654, 656 (7th Cir. 2005) (no Fourth
Amendment violation despite probable cause developing only after officer’s initial
interaction with defendant because initial interaction did not qualify as a seizure).
Harris also asserts that he pleaded a claim under the Equal Protection Clause and
that we should remand for a trial on that issue. But he waived this claim by failing to
raise it first in the district court. See Cooper v. Retrieval-Masters Creditors Bureau, 42 F.4th
675, 688 (7th Cir. 2022). His complaint did not hint at such a claim—the headings and
factual allegations explicitly refer to “unlawful seizure[s]” under the Fourth
Amendment and nothing more. And even though the court repeatedly stated that it
saw only a Fourth Amendment claim, he did nothing to clarify that he intended also to
bring an Equal Protection claim.
AFFIRMED

-- 4 of 4 --