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Neita v. City of Chicago

United States Court of Appeals for the Seventh Circuit
830 F.3d 494 (2016)


Facts

Vaughn Neita (plaintiff) ran a dog-grooming business and rescue shelter. Neita brought two dogs to animal control, one that had attacked and killed another dog and another that had become ill after having puppies. An employee suspected animal abuse and called police. The police arrested Neita and searched his person, vehicle, and business premises. Neita was charged with animal cruelty and neglect, but he was found not guilty on all counts. Exactly two years later, when the applicable limitations period was about to expire, Neita sued the animal-control employee, the police officers, and the City of Chicago (defendants) under 42 U.S.C. § 1983, which allows individuals to sue state officials for constitutional-rights violations. Neita initially alleged that his arrest and the searches of his person and business without probable cause or a warrant violated his constitutional rights, but he omitted the vehicle search. Additionally, Neita raised Illinois state-law claims. The judge dismissed the complaint for failure to state a claim but allowed Neita to replead. Neita amended his complaint and added a claim based on the search of his vehicle. The judge nonetheless found Neita had not adequately pleaded any constitutional violation and that limitations barred the vehicle-search claim. The judge dismissed the federal claims with prejudice and the state-law claims without prejudice to refiling in state court. Neita appealed.

Rule of Law

Issue

Holding and Reasoning (Sykes, J.)

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