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7th Circuit Upholds Dismissal of Police Misconduct Claims

The U.S. Court of Appeals for the Seventh Circuit affirmed a district court's summary judgment dismissal of constitutional and malicious prosecution claims against four Chicago police officers. Oneal Johnson was injured during transport to the police station in April 2019 after refusing to wear a seatbelt and being thrown into a plexiglass divider when the officer braked suddenly.

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Seal of the Seventh Circuit Court of Appeals

Case Information

Case No.:
24-1503
Judges:
Kolar

Key Takeaways

  • Seventh Circuit affirmed dismissal of all constitutional and malicious prosecution claims against four Chicago police officers
  • Plaintiff was injured when thrown into plexiglass divider after refusing to wear seatbelt during police transport
  • Case arose from April 2019 arrest for disorderly conduct at active shooting investigation scene
  • Court applied plaintiff-favorable standard but still found summary judgment appropriate for defendants

The U.S. Court of Appeals for the Seventh Circuit affirmed a lower court's decision to dismiss all claims against four Chicago police officers in a civil rights lawsuit stemming from a 2019 arrest incident. The court issued its decision Jan. 27, 2026, in *Johnson v. Edwards* (7th Cir. 2026), rejecting Oneal Johnson's constitutional and malicious prosecution claims.

Johnson filed the lawsuit against Chicago Police Department officers Ryan Edwards and three other defendants, alleging violations of his constitutional rights and malicious prosecution under Illinois law. All claims arose from a single incident on April 21, 2019, when Johnson was arrested for disorderly conduct at an active crime scene.

According to court records, the incident began around 3:00 a.m. when Johnson was walking toward 75th Street and Champlain Avenue in Chicago. He encountered an active crime scene where Chicago Police Department personnel were investigating a shooting. Police had cordoned off the area with tape as part of their investigation.

The officers concluded that Johnson refused to depart the active crime scene, leading to his arrest for disorderly conduct. The arrest itself was not the primary source of Johnson's injury claims. Instead, Johnson was injured during transport to the police station when a confrontation arose over wearing a seatbelt.

According to the court's recitation of facts, after Johnson was placed in the backseat of a police car, officers attempted to fasten his seatbelt. Johnson refused these attempts by the officers. During the subsequent transport, the officer driving the police vehicle braked suddenly, causing Johnson to be thrown head-first into a plexiglass divider that separated the front and back seats of the police car.

This collision with the plexiglass divider formed the basis of Johnson's constitutional claims against the officers. Johnson alleged that the officers' actions violated his rights under the U.S. Constitution, though the specific constitutional amendments at issue are not detailed in the available portion of the opinion.

Johnson initially filed his lawsuit in the U.S. District Court for the Northern District of Illinois, Eastern Division, before Judge Lindsay C. Jenkins. The case was assigned docket number 1:21-cv-00738, indicating it was filed in 2021, approximately two years after the underlying incident.

The district court ultimately granted summary judgment in favor of all four police officer defendants, dismissing Johnson's constitutional claims and his state law malicious prosecution claim. Summary judgment is appropriate when there are no genuine disputes of material fact and the moving party is entitled to judgment as a matter of law.

Johnson appealed the district court's decision to the Seventh Circuit Court of Appeals, which has jurisdiction over federal appeals from Illinois, Indiana, and Wisconsin. The case was assigned number 24-1503 and came before a three-judge panel consisting of Circuit Judges Amy Coney Barrett, Carl Nichols, and Sarah Pitlyk.

The Seventh Circuit heard oral arguments in the case on Sept. 17, 2025, with Circuit Judge Sarah Pitlyk writing the opinion for the panel. In reviewing the district court's grant of summary judgment, the appellate court was required to view the facts in the light most favorable to Johnson as the non-moving party and draw all reasonable inferences in his favor.

The appeals court cited *James v. Hale*, 959 F.3d 307, 314 (7th Cir. 2020), for this standard of review. This precedent requires courts to accept the plaintiff's version of disputed facts when determining whether summary judgment was appropriate.

Despite applying this plaintiff-favorable standard, the Seventh Circuit affirmed the district court's dismissal of all claims. The court found that the district court correctly granted summary judgment against Johnson on both his constitutional claims and his Illinois state law claim for malicious prosecution.

The decision represents another instance where federal courts have been reluctant to find constitutional violations in cases involving police conduct during arrests and transport. The specific reasoning behind the court's affirmance is not detailed in the available portion of the opinion.

For Johnson, the decision represents the end of his federal court challenge unless he seeks further review from the Supreme Court. The high court accepts only a small percentage of cases for review, typically those involving significant legal issues or conflicts between circuit courts.

The case also highlights ongoing tensions between police conduct and constitutional rights, particularly regarding use of force during arrests and transport. While Johnson's specific claims were unsuccessful, similar cases continue to work their way through federal courts as plaintiffs seek accountability for alleged police misconduct.

The four Chicago police officers defendants successfully defended against all claims and avoided potential monetary damages that could have resulted from a jury verdict in Johnson's favor. The city of Chicago was not named as a defendant in this particular lawsuit.

The procedural history shows the case took several years to work through the federal court system, from the 2019 incident through the 2026 appellate decision, demonstrating the lengthy timeline often required for complex civil rights litigation.

Topics

civil rights violationmalicious prosecutionpolice brutalityexcessive forceFourth Amendment

Original Source: courtlistener

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