In the

United States Court of Appeals

For the Seventh Circuit ____________________ 

No. 22-2467 

TABATHA WASHINGTON and DONTE HOWARD, 

Plaintiffs-Appellants, 

v.

CITY OF CHICAGO, 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. 

____________________ 

ARGUED OCTOBER 24, 2023 — DECIDED APRIL 15, 2024 

____________________ 

Before ROVNER, 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 
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, 
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 detectives’ alleged misrepresentations and omissions is correct, 

plaintiffs cannot meet the second prong of the test in Beauchamp: establishing that those false statements or deliberately 

misleading omissions were “necessary” to the judicial officers’ determinations of probable cause. This is so for two independent 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 judgment 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 twoprong test, we refer to it as the Beauchamp test in this opinion. See 320 F.3d 

at 742–43.
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 investigate. The three parking-lot witnesses each told them of Edmondson’s wounds to the chest and lip, and they told the detectives 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 apartment 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. Howard at first told the detectives they could not enter without a 
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 apartment. 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 coming 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 
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 
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 saying that she did not know his identity but ultimately identifying him as plaintiff Howard, the second man in her apartment 

earlier that evening. The detectives told her they did not believe she was physically capable of causing the fatal damage 

to Edmondson’s head. Washington eventually told the detectives 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 
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 involvement. 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 discussing the altercation in the apartment later that night, 
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 previous 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,” Washington 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 
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 investigation 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 offense.” 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.
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 firstdegree 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 Detectives Alonzo, Garcia, and Balodimas, and the City of Chicago for unlawful pretrial detention under the Fourth 

Amendment and 42 U.S.C. § 1983 and for malicious prosecution 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.” 
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 entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a). 

“We draw ‘all justifiable inferences’ in the favor of the nonmoving party.” Flexible Steel Lacing Co. v. Conveyor Accessories, 

Inc., 955 F.3d 632, 643 (7th Cir. 2020), quoting Anderson v. 
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 
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-legalprocess) 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 summary 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’ probablecause 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 decide this issue here.
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 probablecause determination is predicated solely on a 

police officer’s false statements. Then, too, a person is confined without constitutionally adequate justification. Legal process has gone forward, but it has done nothing to satisfy the 

Fourth Amendment’s probable-cause requirement. 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 essential constitutional wrong is the ‘absence of probable cause 

that would justify the detention.’” Lewis, 914 F.3d at 479, quoting Manuel v. City of Joliet, 903 F.3d 667, 670 (7th Cir. 2018) 

(Manuel II). “Put another way, the initiation of formal legal 
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 received 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 without bail. A few weeks later, Washington and Howard were indicted by a grand jury on charges of first-degree murder, including a felony-murder theory premised on felony mob action. Under Manuel I, these judicial determinations of probable cause do not automatically bar plaintiffs’ Fourth Amendment 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 validity created by the judicial determinations of probable cause at 

their bail hearings and in their indictment. “[T]his presumption 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 
No. 22-2467 17

held that “the presumption may give way on a showing 

[1] that the officer who sought the warrant ‘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, 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 Beauchamp follows logically from the requirement that, “[t]o establish 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 Washington and Howard argue that the police detectives deliberately 

misrepresented certain inculpatory evidence and omitted exculpatory evidence in their communications to the prosecutors, the bail hearing courts, and the grand jury. Plaintiffs 

identify the following conduct by defendant detectives as instances of false statements or omissions: 

False Statements

(1) oral statements to prosecutors that Washington hit Edmondson on the “head” when referring to her blow to his lip;

(2) written statements on the Felony Minutes 

form submitted in Washington’s pretrial 
18 No. 22-2467 

detention hearing that she struck Edmondson 

“on and about the head with a metal object several 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),
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 purportedly overheard by defendant Balodimas, are also disputed 

material facts. Because we construe facts in favor of the nonmoving parties on summary judgment, we must assume they 

were invented by Balodimas. Thus, for the purposes of summary 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 
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 
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 statements (1), (2), and (4), as well as omission (1), as false statements 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 
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 detention 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 defendants’ but-for standard is the correct one. Even the line referencing 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 detention 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 collectively a but-for cause of the judicial determinations of probable cause to detain plaintiffs on first-degree murder charges. 

In this case, two independent reasons bar a finding of butfor causation. First, the State’s Attorney’s Office conducted its 

arguing for something akin to “substantial factor” causation, which applies in the “rare” situation where “multiple sufficient causes independently, 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).
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 Eliminates 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 investigation into the facts before approving charges and presenting the case to the bail courts and the grand jury, any misstatements and/or omissions by the defendant detectives regarding 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, independently “spoke to Defendants and re-interviewed witnesses.” 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 
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 approved 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 indictments.” 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 maintained control over plaintiffs’ prosecution.” Id.

The independent fact-gathering by the State’s Attorney’s 

Office, leading to an independent decision to prosecute plaintiffs, rendered superfluous any lies, misleading statements, or 

omissions by defendants relating to those independently 

gathered facts. See Coleman, 925 F.3d at 351 (overcoming presumption of probable cause requires “evidence that law enforcement obtained the indictment through improper or 

fraudulent means”). If plaintiffs believed the prosecutors had 

also knowingly or recklessly made false or misleading statements about material evidence, they might have tried to sue 

those prosecutors. See Buckley v. Fitzsimmons, 509 U.S. 259, 
No. 22-2467 25

273–74 (1993) (absolute prosecutorial immunity does not extend to prosecutor acting in an investigatory capacity “before 

he has probable cause to have anyone arrested”).

The prosecutor’s independent investigation alone is sufficient reason to affirm summary judgment. It renders the purported misstatements and omissions by the detective defendants 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 judicial 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 believe,” that, in this case, Washington and Howard killed Edmondson. 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 
26 No. 22-2467 

instance, on the elements of the predicate criminal offense(s) 

as defined by state law.” (alterations in original; internal citation 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 showing of such activity,” so it “is not a high bar.” District of Columbia v. Wesby, 583 U.S. 48, 57 (2018) (internal quotations 

omitted).

Probable cause is “‘assessed objectively’ based on ‘the conclusions that the ... officer reasonably might have drawn from 

the information known to him.’” Young, 987 F.3d at 644, quoting 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 sufficient 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 detention hearings, “the facts and circumstances within [the officer’s] knowledge and of which he had reasonably trustworthy 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, 
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 admitted 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 Edmondson’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” behavior, as both Washington and Howard had by lying in their 
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, including the identities of others involved in the offense. Johnson v. 

Pollard, 559 F.3d 746, 754 (7th Cir. 2009) (“The fact that an officer misrepresents the strength of the evidence against a defendant is insufficient, standing alone” to render a resulting 

confession unreliable). Indeed, the detectives’ interrogation 

on this point was fruitful. Washington eventually told the detectives 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 Waller 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 
No. 22-2467 29

judgment because probable cause existed at time of arrest despite later recantation of accusation and allegedly coercive interrogation”). 

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 feeding 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 Edmondson’s head, even when he turned and walked away 

from them. And Edmondson had been able to maintain a conversation with those witnesses, describing to them the altercation 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 detectives 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 probable 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 evidence 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.
30 No. 22-2467 

Plaintiffs rely on other cases finding a lack of probable 

cause to support pretrial detention, but they are distinguishable. 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 contemporaneous 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 siblings had dumped [the victim’s] body ... was true, the body 

would have had to float upstream four to six miles to have arrived 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 established 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 
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 apartment, 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, initially thought that Ruth had been shot. Rainsberger 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 
32 No. 22-2467 

take a polygraph test. A week later, they voluntarily 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 children 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 circumstances support[ed] nothing more than bare suspicion....” Id. at 649. “If probable cause exists here, then anyone 

who experiences the tragedy of discovering a murdered family member—and who correctly assesses the cause of the injury 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. 
No. 22-2467 33

And even if the detectives did not believe Washington alone 

was capable of dealing the fatal blow, the charged felonymurder theory did not require that she did.

Consequently, after eliminating the alleged misrepresentations and adding in the omissions, undisputed facts show 

that probable cause would have still existed to detain Washington 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 statements 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 judicial 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 
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.